Income tax objections
The majority of low complexity objections now being assigned to an appeals officer were received in January 2018. Objections resolved in March 2018 were completed in an average of 81 days from the date the objection was submitted. For the service standard relating to low complexity tax objections, go to Service Standards in the CRA. In the 2017-2018 fiscal year, the CRA met its low complexity income tax objections service standard 81% of the time, up from 61% at the end of April 2017.
The majority of medium complexity objections now being assigned to an appeals officer were received in April 2017. Objections resolved in March 2018 were completed in an average of 314 days from the date the objection was submitted. For the service standard relating to medium complexity objections, go to Service Standards in the CRA.
High complexity objections take significantly longer to resolve than other objections due to their technical complexity and represent only two to three percent of the CRA’s total Objections Program workload. On average, it may take over 690 days to resolve high complexity income tax objections. During this period, CRA representatives are in regular contact with the taxpayers who have filed these objections.
The CRA has undertaken a comprehensive review of its objection-related processes in order to further streamline its processes and gain efficiencies that will contribute towards providing more timely and efficient service to taxpayers.
The number of days taken by the CRA to resolve an objection excludes the time taken by taxpayers to provide additional information to support their objection.
For definitions of complexity, see Are there different levels of complexity for objections?
What happens if I do not agree with the Notice I received from the CRA about my income tax or I have more information to provide?
If you have received a Notice of Assessment, Notice of Reassessment, Notice of Determination, or Notice of Redetermination and you do not think that it is correct or you have additional information for CRA to consider, please review the following Questions to determine the best course of action for you to take.
1. Do you want to provide the Canada Revenue Agency (CRA) with missing information for a tax return you have filed with us previously?
If so, rather than filing an objection, generally you can ask for a change to a personal tax return (T1) for a tax year ending in any of the 10 previous calendar years. For example, a request made in 2016 must relate to the 2006 or a later tax year to be considered. You will find the steps to follow and processing timeframes by visiting www.cra.gc.ca/changereturn.
You can also ask for a change to a corporate tax return (T2). You will find the steps to follow by visiting Requesting a reassessment of your T2 return.
The Voluntary Disclosures Program gives you a second chance to change a tax return you previously filed or to file a return that you should have filed. You can apply to the CRA to ask for relief of prosecution and penalties. www.cra.gc.ca/voluntarydisclosures/
2. Did the CRA send you an income tax assessment notice for a tax year that you had not previously filed a tax return and did you want to provide the CRA with information that may change that assessment?
If so, rather than filing an objection, you can still send your tax return to CRA. Information on how to send us your return can be found here by visiting Send us your return.
3. Did you submit your receipts and records to CRA and you did not receive the outcome you expected or the issue was not resolved to your satisfaction? This means, that you provided the requested information to CRA and you received your Notice of Assessment, Notice of Reassessment, Notice of Determination, or Notice of Redetermination and you think we have misinterpreted the facts or applied the law incorrectly.
You may have the right to object and submit an objection. Information about filing an objection can be found below.
Please note that if you received a request to provide information during an audit or were otherwise contacted by CRA with a request to provide additional information and you did not respond to those requests and you chose instead to provide this information as part of an objection, your information may be referred back to the original area for a second review.
Can I file an income tax objection?
You or your authorized representative can file an income tax objection if you have received any of the following:
- Notice of Assessment;
- Notice of Reassessment;
- Notice of Determination; or
- Notice of Redetermination.
You cannot file an objection to dispute the following:
- a Statement of Account , or
- a proposal letter from an auditor.
You are required to clearly explain why you disagree with the assessment or determination and also include all of the relevant facts and reasons.
The time limits for filing an objection are as follows:
If you are an individual:
- the time limit for filing an objection is whichever of the following two dates is later:
- one year after the date of the filing deadline for the return (April 30 or June 15), or
- the day that is 90 days after the day of sending the Notice of Assessment (the date of the notice or notification).
If you are a business or for assessments of taxes in respect of over-contributions to a registered retirement savings plan (RRSP) or tax-free savings account (TFSA):
- the time limit to file an objection is within 90 days of the day we sent the Notice of Assessment or Reassessment (the date of the notice or notification).
For information about RRSP excess contributions, go to www.cra.gc.ca/rrsp.
For information about TFSA excess contributions, go to www.cra.gc.ca/tfsa.
If you did not file your objection on time because you attempted to have your change made by contacting the originating CRA office or because of circumstances beyond your control, you can apply for a time extension to file an objection. You can apply by writing to the Chief of Appeals at your Appeals Intake Centre (see Appendix B of pamphlet P148), or by using the My Account or My Business Account online services. You have to explain why you did not file your objection on time along with the facts and reasons of your objection.
The application for a time extension to file an objection must be made within one year after the expiration of the time limit to file an objection.
How do I file an income tax objection?
Here is what you provide when you file an income tax objection:
- clear details of the issue(s) you are disputing, for example: I received a reassessment and my expenses were reduced because my receipts were disallowed. I believe that my receipts qualify as proof of my expenses because (insert reasons), and
- any documentation to support your claim.
For an example of an income tax objection letter, see Appendix A of pamphlet P148 Resolving your dispute: Objection and appeal rights under the Income Tax Act.
You will find the steps to follow to file an objection and processing timeframes below. It is important to always provide all relevant information to CRA to allow for a complete consideration of the issue, at the assessing, audit, and objection stages.
You or your authorized representative can file an objection in one of the following ways:
- online at My Account by selecting "Register my formal dispute";
- online at My Business Account by selecting "Register a formal dispute (Notice of Objection)" for “Corporations”;
- online at Represent a Client; or
- by mail, using Form T400A, Objection – Income Tax Act, or in writing to the chief of appeals at your Appeals Intake Centre (see Appendix B of pamphlet P148).
In all cases, you should clearly explain why you disagree and include all relevant facts, reasons, and supporting documents.
For more information on the Submit Documents online service, go to Submit documents online.
How long will my objection take?
The time it takes to complete the review of an objection varies.
Factors that influence the time it takes include:
- the complexity of the issue, and
- delays caused by not submitting all the facts, reasons and documentation.
Your objection may be assigned sooner, if your submission is clear and complete.
Are there different levels of complexity for objections?
Low complexity objections:
These objections often involve issues such as: individual tax credits, personal deductions, Canada Child Benefit, and Disability Tax Credit.
Medium complexity objections:
These objections often involve issues such as: business expenses and more complex T1 issues.
High complexity objections:
These objections involve large corporations, complex business transactions, international transfer pricing, and General Anti-Avoidance Rule assessments.
Scientific Research and Experimental Development (SR&ED) objections:
Consulting with specialists is often required to resolve these objections.
Tax avoidance schemes:
For information on tax avoidance see Tax Avoidance and Cracking down on offshore tax evasion and aggressive tax avoidance.
When will an appeals officer look at my objection?
Low and medium complexity objections:
For the objection resolution timelines for low and medium complexity objections, refer to the Objections Assignment and Resolution Timelines box at the top of this page.
High complexity objections:
High complexity income tax objections on average may take over 690 days to resolve. During this period, CRA representatives are in regular contact with the taxpayers who have filed these objections.
Scientific Research and Experimental Development (SR&ED) objections and Tax avoidance schemes:
Due to the complex nature of the issues involved, at this time we cannot provide a timeframe for the resolution of these objections.
How can I have my objection resolved faster?
There is a lot you can do to speed up the processing of your objection. To have your objection resolved faster:
- ensure that all explanations and documentation are provided as early in the process as possible
- ensure that your concerns are fully explained and supported
- submit the objection electronically using My Account, My Business Account or Represent a Client.
What causes delays during the objection review?
Your objection may take longer if:
- it is not clear what you are objecting to
- you do not provide the facts, reasons, and supporting documentation with your objection
- the appeals officer needs to consult other CRA tax specialists
- there is an appeal to the courts that may cause your objection to be held in abeyance, pending the outcome
- if you do not submit your objection electronically using My Account, My Business Account or Represent a Client.
You will be notified if more information is required or your objection is delayed.
What do I do if I don’t agree with the decision made in regards to my objection?
Once you receive CRA's decision resulting from an objection, you can appeal your assessment or determination to the Tax Court of Canada, either under the Informal Procedure or the General Procedure. The time limit for filing an appeal is 90 days from the date on the notice. The Tax Court procedures are explained in publication P148, Resolving Your Dispute: Objections and Appeal Rights under the Income Tax Act. You can appeal the Tax Court's decision to the Federal Court of Appeal, and a judgment of the Federal Court of Appeal can be further challenged before the Supreme Court of Canada, with the Court's permission.
Time Extension – Notice of Appeal
You can apply for an extension to file your appeal by making an application to the Tax Court of Canada. Explain why you cannot or did not file your appeal on time.
Apply as soon as possible, but the application must be made within one year after the expiration of the time limit to file an appeal.
Amounts owing that are under a formal review
In most cases, you do not have to pay income tax amounts that are in dispute until the CRA has completed its formal review or, if you have filed an appeal, until the Tax Court of Canada issues its decision or you withdraw your appeal. In addition, if you file an objection and have previously paid an amount toward an assessment or reassessment, you may ask us to repay the amount you paid that is in dispute. If you are entitled to a repayment, we will first apply the amount to reduce or clear any other amounts you owe that are not in dispute. We will refund the remainder.
It is important to note that interest charges apply during any period that an amount in dispute is not paid/refunded. You can pay all or part of the amount, and you will receive a refund with interest if you are successful.
The Minister may grant relief from penalties or interest in certain circumstances. For more information, visit Cancel or waive penalties or interest.
While an application for taxpayer relief from interest or penalties is under consideration, collection action will continue on any undisputed amount and the amount is due and payable. For more information on collections, visit When you owe money-collections at the CRA.
After the decision -- Collection action resumes on amounts owed
Once the decision rendered on the objection has been issued, any amounts owed that are no longer under dispute would be payable, including taxes, penalties, and interest where applicable. Collection action following an objection, is usually delayed until 90 days after we send our decision to you.
Who do I contact if I have questions about the status of my objection and I have not yet been contacted by an appeals officer?
If you have not yet been contacted by an Appeals Officer, or do not have the officer's contact information, you may contact one of the Intake Centres:
Eastern Intake Centre
Toll Free Public Enquiries Line: 1-866-242-3161 (English), 1-866-276-0969 (French)
Local Public Enquiries Line: 705-671-0238 (English), 705-677-7764 (French)
Fax: 1-866-443-4955, Local: 705-671-0388
Western Intake Centre
Public Enquiries Line: 1-800-959-5513
Fax: 1-866-489-6832, Local: 604-587-2672
Residents with a Postal Code starting with letters A to P may contact the Eastern Intake Centre, and residents with a Postal Code starting with letters R to Y may contact the Western Intake Centre.
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