Notice of Objection and Appeals Support for CRA Assessments You Disagree With
If a notice of assessment or reassessment gets your tax wrong, you have a limited time to dispute it. Bestax reviews the CRA’s adjustments, tells you whether an objection is worth filing, and prepares one built on the facts, the law and the documents.
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When a Notice of Objection Makes Sense
An objection is the formal way to ask the CRA to review an assessment it has already issued. It goes to the CRA’s Appeals Division, which looks at the file separately from the officer who made the adjustment.
- A reassessment after an audit or review that denied expenses, credits or deductions you were entitled to.
- Income the CRA added that was not yours, was already reported, or is not taxable.
- Penalties, such as gross negligence penalties, that you believe do not fit what happened.
- A GST/HST assessment that denied input tax credits or treated supplies as taxable.
- A business or rental loss, or a capital gain treated as income, that changes the tax substantially.
- A missed objection deadline that may still be open to an extension request.
An objection is not the place for new information the CRA never asked for during the audit. The stronger the record at the review stage, the stronger the objection.
Still in the middle of a review or audit? Start with our CRA Audit & Review Support. Correcting something the CRA has not found yet? See Voluntary Disclosures.
What Our Objection Service Covers
From reading the notice to the Appeals Division’s decision, we prepare each part of the dispute and keep the record consistent.
- A review of the notice and the CRA’s adjustments, and an honest view of whether objecting is worth it.
- Calculation of the deadline that applies to you, and an extension request if it has passed.
- Preparation of the objection on Form T400A, through My Account or My Business Account, or in writing.
- GST/HST objections on Form GST159, with the input tax credit and supply records behind them.
- Supporting submissions that set out the facts, the law and the documents for each issue.
- Our authorization to act for you, and handling of the appeals officer’s questions until a decision is made.
The Deadlines That Decide an Objection
For income tax, the general deadline is 90 days after the date on the notice of assessment or reassessment. Individuals, other than trusts, and graduated rate estates have the later of that date and one year after the filing due date of the return being assessed.
If the deadline has passed, you can ask the CRA for an extension within one year after it, with the reasons you could not object in time. Extensions are not automatic, so a file should never be planned around one.
Object within 90 days of the notice date, or within the one-year window where it applies to you.
Address every issue you dispute, with the facts, the reasons and the relief you are asking for.
File on Form T400A, through My Account or My Business Account, or by letter; GST/HST uses Form GST159.
Interest keeps running on any amount you do not pay, and is charged on the tax if the objection fails.
An objection that is late, or that does not explain why the assessment is wrong, rarely gets the review it needs.
From Notice to Tax Court: Each Stage
A dispute moves through set stages, each with its own deadline. Missing one generally makes the assessment final for that issue.
| Stage | What is filed | Deadline | What happens to collection |
|---|---|---|---|
| Income tax objection | Form T400A, My Account or My Business Account, or a letter | 90 days after the notice date, or one year after the filing due date for most individuals | Generally held back on the disputed tax, except part of it for large corporations |
| GST/HST objection | Form GST159 or an online objection | 90 days after the notice date | Not held back; the CRA can collect while the objection is reviewed |
| Extension of time to object | A request with the reasons for the delay | Within one year after the objection deadline | The assessment stands until an extension is granted |
| Appeal to the Tax Court of Canada | A notice of appeal to the Court | 90 days after the CRA’s decision, or after 90 days with no decision | Income tax generally still held back while the appeal is pending |
Payroll source deductions are collectable while they are disputed, and CPP and EI questions follow their own appeal route.
What We Need to Prepare Your Objection
Appeals officers decide on what is in front of them, so an objection is only as strong as the records behind it.
Where documents are missing, we look for third-party records that prove the same facts, such as bank statements, contracts or supplier confirmations.
- The notice of assessment or reassessment, with its date.
- The CRA’s audit or review letters and its explanation of the adjustments.
- The return as filed for the year in dispute.
- Receipts, invoices, contracts and bank records for each disputed item.
- Any correspondence you or a representative have had with the CRA on the file.
- For GST/HST: the returns for the periods involved and the supporting sales and purchase records.
Our Notice of Objection Process
Review the notice
We read the assessment and the CRA’s reasons, and confirm the deadline that applies to you.
Weigh the dispute
We compare the tax at stake with the strength of your position, and tell you if accepting is the better choice.
Build the record
We gather the documents and facts for each issue and match them to the law that applies.
File the objection
We prepare the objection with you, review it together, and file it on time as your representative.
Deal with Appeals
We answer the appeals officer’s questions and respond to any proposal until a decision is issued.
Next steps
If the decision goes against you, we explain the Tax Court options and work with counsel where one is needed.
Why Clients Choose Bestax for a Tax Objection
A straight assessment
We tell you when an objection is worth the time and cost, and when it is not.
Deadlines kept
We confirm your deadline at the first call, because a late objection is rarely heard.
Built on evidence
Each issue is argued with the facts, the law and the documents, not general disagreement.
One point of contact
With your authorization, the appeals officer deals with us rather than with you.
Counsel when needed
Bestax does not give legal advice. Where a Tax Court appeal needs a lawyer, we work alongside your counsel with the figures and records.
Related Bestax Services
CRA Audit & Review Support during the review or audit, before a reassessment is issued.
GST/HST Returns for accurate filings once a GST/HST dispute is resolved.
T2 Corporate Tax Returns for corporations whose returns were reassessed.
Personal Tax Returns for individuals keeping later years consistent with the outcome.
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Frequently Asked Questions
For income tax, generally 90 days after the date on the notice of assessment or reassessment. Individuals, other than trusts, and graduated rate estates can file by the later of that date and one year after the filing due date of the return. GST/HST objections must be filed within 90 days.
Not always. You can ask the CRA for an extension of time within one year after the objection deadline, explaining why you could not object in time. The CRA decides whether to grant it, so it is best to act as soon as you notice the deadline has passed.
For income tax, the CRA generally does not collect the disputed amount while the objection or appeal is pending, although large corporations must generally pay part of it. GST/HST and payroll amounts can be collected despite the objection. Interest runs throughout, so paying can sometimes be the cheaper choice.
It deals with each disputed issue separately, sets out the facts, explains why the law supports your position, and attaches the documents that prove it. An objection that only says the assessment is wrong gives the appeals officer nothing to work with.
You can appeal to the Tax Court of Canada within 90 days after the CRA’s decision, or after 90 days if the CRA has not decided. Smaller disputes can use the Court’s informal procedure; larger ones go through the general procedure, a formal process where you should be represented by a tax lawyer.
Yes. With your authorization, we prepare and file the objection and handle the appeals officer’s questions. For a Tax Court appeal, we provide the figures and records and work with your lawyer, since Bestax does not give legal advice.