Objections and appeals: Registered charities, registered Canadian amateur athletic associations (RCAAAs), and other listed qualified donees

If you think we have misinterpreted the facts or applied the law incorrectly, you have the right to object to a notice or an assessment.

The first step in the formal process of resolving a dispute is filing an objection. The time limit for filing an objection is 90 days from the date on the notice. You can file an objection by writing to:

Assistant Commissioner
Appeals Branch
250 Albert Street, 13th Floor
Ottawa ON  K1A 0L5

In all cases, you have to explain why you disagree and include all relevant facts and supporting documents.

You or your authorized representative can also submit your objection and supporting documents online at My Business Account, or Represent a Client, by selecting the “Submit documents” service.

For more information on the Submit Documents online service, go to Submit documents online.

Filing an appeal to the courts

If you disagree with the CRA's decision resulting from an objection in Category A, you can appeal to the Federal Court of Appeal. The time limit for filing an appeal is 30 days from the date on the notice. The Federal Court of Canada judgment can, in turn, be challenged before the Supreme Court of Canada, with that Court's permission.

If you disagree with the CRA's decision resulting from an objection in Category B, you can appeal to the Tax Court of Canada, either under the Informal Procedure or the General Procedure. These procedures are explained in Appealing Income Tax Act Assessments and Notices in respect of Registered Charities to the Tax Court of Canada. The time limit for filing an appeal is 90 days from the date on the notice. If you are not satisfied with the judgment of the Tax Court of Canada, you can appeal 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 that Court's permission.

Registered charities may object to notices or assessments regarding:

Category A

  • designations
  • proposals or decisions to refuse, annul or revoke registration

Category B

  • income tax assessments and reassessments of tax and penalties
  • notices of suspension of tax–receipting privileges

RCAAAs may object to notices or assessments regarding:

Category A

  • proposals or decisions to refuse or revoke registration

Category B

  • income tax assessments and reassessments of penalties
  • notices of suspension of tax–receipting privileges

Other qualified donees may object to notices regarding:

Category A

  • decisions to refuse registration of:
    • low–cost housing corporations for the aged,
    • municipal or public bodies performing a function of government in Canada
  • proposals to revoke registration of all other listed qualified donees

Category B

  • notices of suspension of tax–receipting privileges

For more information, you may leave a message in the voice mailbox at 613-960-2447, send a fax to 613-941-8088, or send an email to Appeals.CRS/Appels.SRMB@cra-arc.gc.ca.

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