Corporate Notice of Objection Deadline Calculator
A corporation gets ninety days, not the longer period individuals get. Work out your exact deadline, the extension date behind it, whether collections stop when you object, and what has to be in the objection itself.
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The Dates
| Milestone | Basis | Date | Status |
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What Happens to Collections
| Situation | Position While Objecting |
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What the Objection Must Contain
| Element | Why |
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Points That Decide This
What to Do Next
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Disclaimer: Under subsection 165(1) a corporation must serve a notice of objection within ninety days of the date of the notice of assessment or reassessment. The longer alternative period available to individuals and graduated rate estates does not apply to corporations. Where the deadline is missed, an application for an extension may be made under sections 166.1 and 166.2 within one year after the ninety days expire, and the applicant must show it was unable to act within the period and applied as soon as circumstances permitted. For GST/HST, section 301 of the Excise Tax Act sets the same ninety day period. Subsection 225.1(1) generally restricts collection of income tax while an objection is outstanding, but subsection 225.1(7) allows collection of half the amount from a large corporation, and the Excise Tax Act contains no equivalent restriction so GST/HST collection may continue. A large corporation must, under subsection 165(1.11), reasonably describe each issue, specify the relief sought and provide the facts and reasons, and issues not raised cannot generally be added later. This page is general information, not tax or legal advice.
Corporations Get Ninety Days. Individuals Get Longer.
Individuals objecting to an assessment have until the later of ninety days from the notice and one year after their filing due date. A corporation has ninety days and nothing else.
Owner-managers who have objected personally in the past assume the same rule applies to the company. It does not. The date on the notice starts a ninety day clock, and it runs from the date printed on the notice rather than the day it arrived or the day you opened it.
Missing It Is Not Necessarily Fatal
An application for an extension can be made within one year after the ninety days expire, so the outside limit is roughly one year and ninety days. It is not automatic, and you have to show you were unable to act within the period and applied as soon as circumstances permitted.
| Position | Route |
|---|---|
| Within ninety days | Object as of right |
| Ninety days to one year and ninety days | Apply for an extension, and explain the delay |
| Beyond that | The assessment is final |
Being unaware of the deadline is generally not a good reason. Illness, absence and not having received the notice are stronger, and the application has to be supported rather than asserted.
An HST Objection Does Not Stop Collections
This is the distinction that surprises people most. For income tax, subsection 225.1 generally restricts collection while an objection is outstanding. The Excise Tax Act has no equivalent, so the CRA can continue collecting on an HST assessment throughout.
| Assessment | Collections While Objecting |
|---|---|
| Income tax, ordinary corporation | Generally suspended |
| Income tax, large corporation | Half the amount remains collectable |
| GST/HST, any corporation | Collection continues |
A corporation objecting to an HST assessment and assuming the money is safe until the objection is decided can find its bank account garnished in the meantime. Where that is the position, a payment arrangement should be negotiated alongside the objection rather than after it.
The Large Corporation Trap
A corporation with taxable capital over $10,000,000 must reasonably describe each issue, specify the relief sought for each, and provide the facts and reasons. Issues not raised in the objection generally cannot be added later, including at the Tax Court.
That turns a procedural formality into a substantive one. A short objection saying the assessment is wrong preserves nothing, and there is no route back once the ninety days have gone.
What to Do With the Time You Have
- Diarise the date immediately, working from the date on the notice.
- Get the auditor’s report and working papers, which explain how the numbers were built.
- Identify every issue, not just the largest, because narrowing later is easy and adding later is not.
- File the objection even if the analysis is incomplete, since it can be supplemented but not resurrected.
- Deal with collections separately, particularly on HST where nothing stops automatically.
- Consider whether relief on penalties and interest should be applied for alongside, since that is a separate process.
Filing a thin objection on time beats a thorough one filed late. An objection can be expanded with submissions afterwards. A missed deadline requires an extension application you may not get. Our objections and appeals service covers the filing, the submissions and the collections position.
What This Calculator Does Not Cover
- Tax Court appeal deadlines, which follow the objection stage
- Whether your objection has merit, which is the substantive question
- Taxpayer relief applications on penalties and interest, a separate process
- Payroll and source deduction assessments, which have their own rules
- Provincial assessments outside the CRA’s administration
- Judicial review of discretionary decisions
Frequently Asked Questions
Common questions on objecting to a CRA assessment.
Related Calculators and Guides
More tools for CRA disputes.
A Thin Objection Filed on Time Beats a Thorough One Filed Late
Send us the notice and the auditor’s report. We will identify every issue, file the objection inside the deadline, and deal with the collections position separately where the assessment is HST.