CRA Notice of Objection — Income Tax Act s.165
Formal Notice of Objection to the Chief of Appeals at a CRA Tax Services Office or Tax Centre under Income Tax Act (R.S.C. 1985, c. 1 (5th Supp.)) s.165. Triggers Minister's reconsideration under s.165(3) and preserves right of appeal to the Tax Court of Canada under s.169. Deadlines: individuals + graduated rate estates — later of 1 year after filing-due date OR 90 days after Notice of Assessment (s.165(1)(a)); corporations + other taxpayers — 90 days after Notice of Assessment (s.165(1)(b)). Federal letter scales across all 10 provinces + 3 territories. UPL-safe — CRA Appeals intake is designed for self-filers.
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Taxpayer + Assessment Identification
Identifies you (the taxpayer), the assessment being objected to, and the deadline that applies — the deadline differs for individuals versus corporations.
This letter will cite
Income Tax Act (R.S.C. 1985, c. 1 (5th Supp.)) s.165(1) — Notice of Objection filing deadline; s.165(2) — addressing requirements; s.169 — appeal to Tax Court of Canada; s.165(3) — Minister's reconsideration; s.165(7) — appeal without further objection
This Notice of Objection preserves your right to appeal to the Tax Court of Canada under s.169 if CRA confirms the assessment or fails to respond within 90 days.
Individuals + graduated rate estates use the longer of two deadlines under s.165(1)(a). Corporations and other taxpayers must file within 90 days of the Notice of Assessment under s.165(1)(b).
CRA cannot process an objection without correct taxpayer identification. Format with spaces and the account suffix (e.g., RC0001 for corporate income tax).
Each tax year is a separate assessment. List every year covered by the assessment(s) you are objecting to.
The 90-day clock under s.165(1)(b) runs from the date the notice was SENT (per the notice itself), not the date you received it. The 1-year alternative for individuals under s.165(1)(a)(i) runs from filing-due date for the year.
T1 filing-due date is typically April 30 (or June 15 for self-employed individuals). For corporations and other taxpayers, this field is not used — only the 90-day rule applies.
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