Objections and Appeals in Alberta
Reviewed by the Commoner Law Editorial Team. Sourced from Canadian federal statutes and official sources. Provincial information reflects each province's own legislation and court rulings. Written in plain language for general understanding — this is educational content, not legal advice. Our editorial standards
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 to Do If You Disagree with a CRA Tax Assessment in Canada
- 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.
How Alberta differs from federal law
If you disagree with a CRA assessment or reassessment of your federal or Alberta provincial income tax, you have the right to formally object and, if necessary, appeal to court.
- You can file a Notice of Objection within 90 days of the date on the notice of assessment or reassessment. For individuals, you can also file within 1 year of the filing due date, whichever is later.
- The objection is reviewed by a CRA Appeals Division officer who was not involved in the original assessment. This is an independent internal review.
- If you are unsatisfied with the CRA's decision on your objection, you can appeal to the Tax Court of Canada within 90 days of the CRA's decision. The Tax Court has sittings in Calgary and Edmonton.
- The Tax Court offers two procedures: the informal procedure (for amounts under $25,000 per year or losses under $50,000) is simpler and faster, and the general procedure for larger amounts.
- Further appeals go to the Federal Court of Appeal and then potentially the Supreme Court of Canada.
Additional Steps in Alberta
File your Notice of Objection online through CRA My Account, by mail using Form T400A, or by contacting your local Tax Services Office. In Alberta, the CRA offices are located in Calgary and Edmonton. If you need help at the Tax Court, Legal Aid Alberta does not generally cover tax matters, but the Tax Court's informal procedure is designed for self-represented taxpayers. You can also contact a tax lawyer through the Law Society of Alberta at 1-800-661-1095.
Relevant Law: Income Tax Act, RSC 1985, c. 1 (5th Supp.), ss. 165–169 (Objections and Appeals); Tax Court of Canada Act, RSC 1985, c. T-2
Common Questions
When does objections and appeals 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 I do if the CRA assessed me incorrectly and I want to dispute it in Canada?
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 mistakes should I avoid with objections and appeals?
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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