Objections and Appeals — Quebec
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 an assessment or reassessment, you can file a Notice of Objection under section 165. This is the formal first step — and the one most people miss because the deadline is short.
For individuals, you have the later of 90 days from the assessment date or one year after the return's filing due date. For corporations, it's 90 days only. The Act does not extend these clocks generously.
Once filed, the case moves to a CRA Appeals officer who reviews it independently from the auditor who made the original decision. That separation matters — it's the first time fresh eyes look at your file.
Still unsatisfied? Appeal to the Tax Court of Canada within 90 days of the Appeals decision. For disputes under $25,000, the Informal Procedure is the way: simpler rules, faster timelines, no lawyer required.
And if the CRA goes silent for 90 days after your objection, you can skip the wait and head straight to Tax Court under section 169.
When does it apply?
Applies to any taxpayer who's received a Notice of Assessment or Reassessment they disagree with.
- Individuals: the later of 90 days or one year after the filing deadline.
- Corporations: 90 days, period.
- A late-filed objection can sometimes be accepted within one additional year under s. 166.1, but only if you can explain the delay.
What to Do If You Disagree with a CRA Tax Assessment in Canada
- Mark the 90-day deadline the moment the assessment lands.
- File Form T400A through My Account or by mail.
- Lay out the issues, the relevant facts, and the legal basis — vague objections drift.
- Wait for the Appeals officer to make contact. They will.
- If you still disagree, file with the Tax Court of Canada within 90 days of the decision.
- If CRA hasn't responded after 90 days, go straight to Tax Court — you don't have to wait.
What should you NOT do?
- Don't miss the 90-day deadline. The most common and costliest mistake in Canadian tax practice.
- Don't assume objection equals no payment. Individuals get collection postponed, but large corporations have to pay 50% upfront.
- Don't file vague objections. Spell out what you disagree with and why.
- Don't confuse a service complaint with a formal objection. Different processes, different outcomes — the service complaint route doesn't preserve appeal rights.
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
What is the objections and appeals right in Canada?
If you disagree with an assessment or reassessment, you can file a Notice of Objection under section 165. This is the formal first step — and the one most people miss because the deadline is short.For individuals, you have the later of 90 days from the assessment date or one year after the return's filing due date. For corporations, it's 90 days only. The Act does not extend these clocks generously.Once filed, the case moves to a CRA Appeals officer who reviews it independently from the auditor who made the original decision. That separation matters — it's the first time fresh eyes look at you...
When does objections and appeals apply?
Applies to any taxpayer who's received a Notice of Assessment or Reassessment they disagree with.Individuals: the later of 90 days or one year after the filing deadline.Corporations: 90 days, period.A late-filed objection can sometimes be accepted within one additional year under s. 166.1, but only if you can explain the delay.
What should I do if the CRA assessed me incorrectly and I want to dispute it in Canada?
Mark the 90-day deadline the moment the assessment lands.File Form T400A through My Account or by mail.Lay out the issues, the relevant facts, and the legal basis — vague objections drift.Wait for the Appeals officer to make contact. They will.If you still disagree, file with the Tax Court of Canada within 90 days of the decision.If CRA hasn't responded after 90 days, go straight to Tax Court — you don't have to wait.
What mistakes should I avoid with objections and appeals?
Don't miss the 90-day deadline. The most common and costliest mistake in Canadian tax practice.Don't assume objection equals no payment. Individuals get collection postponed, but large corporations have to pay 50% upfront.Don't file vague objections. Spell out what you disagree with and why.Don't confuse a service complaint with a formal objection. Different processes, different outcomes — the service complaint route doesn't preserve appeal rights.
Objections and Appeals in other states
Same topic, different jurisdiction. Pick the one that applies to you.