Objections and Appeals
Written in plain language for general understanding. This is educational content, not legal advice. Based on Canadian federal statutes and official sources.
What is this right?
If you disagree with a CRA assessment or reassessment, you can file a Notice of Objection under Section 165 of the Income Tax Act.
For individuals, the deadline is the later of 90 days from the date of assessment or one year after the filing deadline for that tax year. For corporations, the deadline is 90 days only.
Once you file, a CRA Appeals officer reviews your case independently from the auditor who made the original decision. This is a fresh look at your situation.
If you are still unsatisfied after the Appeals review, you can appeal to the Tax Court of Canada within 90 days of the CRA's decision. The Informal Procedure is available for disputes under $25,000 — it is simpler, faster, and you do not need a lawyer.
If the CRA has not responded to your objection within 90 days, you can go directly to Tax Court without waiting (Section 169).
When does it apply?
This applies to any taxpayer who has received a Notice of Assessment or Reassessment they disagree with.
- Individuals have the later of 90 days or one year after the filing deadline.
- Corporations have 90 days only.
- Late-filed objections may be accepted if you apply within one additional year under Section 166.1.
What should you do?
- Act quickly — mark the 90-day deadline on your calendar as soon as you get your assessment.
- File Form T400A online through My Account or by mail.
- Clearly state the issues, relevant facts, and legal basis for your disagreement.
- Wait for the Appeals officer's review — they will contact you to discuss.
- If still unsatisfied, file with the Tax Court of Canada within 90 days of the CRA's decision.
- If CRA has not responded within 90 days, you can go directly to Tax Court.
What should you NOT do?
- Don't miss the 90-day deadline — this is the most common and costly mistake taxpayers make.
- Don't assume filing an objection means you don't have to pay — individuals get a postponement of collection, but large corporations must pay 50% upfront.
- Don't file a vague objection — clearly explain what you disagree with and why.
- Don't confuse a service complaint with a formal objection — they are different processes with different outcomes.
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