Objections and Appeals in Quebec
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 Quebec differs from federal law
If you disagree with a Revenu Quebec assessment, you have the right to formally object and appeal. Quebec has its own objection process that is separate from the CRA process.
- You can file a notice of objection with Revenu Quebec within 90 days of the date of the notice of assessment (or reassessment) you are contesting. Use form MR-93.1.1 or file through your My Account on the Revenu Quebec website.
- The objection is reviewed by a Revenu Quebec officer who was not involved in the original assessment. The officer may confirm, vary, or vacate the assessment.
- If you are not satisfied with the objection decision, you can appeal to the Court of Quebec (Administrative and Appeal Division) within 90 days of the objection decision. This is different from the federal process, where appeals go to the Tax Court of Canada.
- You can also appeal certain decisions to the Court of Quebec, Small Claims Division if the amount in dispute is $15,000 or less.
- Filing an objection does not stop collection — you must pay the assessed amount or negotiate a payment plan. However, you can apply for the suspension of collection measures in certain circumstances.
Additional Steps in Quebec
File your objection within 90 days of the assessment. Use the Revenu Quebec My Account portal or mail Form MR-93.1.1. Clearly explain why you disagree and include supporting documents. If the objection decision is unfavorable, consult a tax lawyer about appealing to the Court of Quebec.
Relevant Law: Tax Administration Act (CQLR c A-6.002), ss. 93.1.1-93.1.15; Taxation Act (CQLR c I-3)
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.
Legal Resources
We may earn a commission if you use these services — at no extra cost to you. This supports our mission to make legal information free for everyone.