Objections and appeals – Registered charities and other qualified donees
This information is for registered and revoked charities, other qualified donees, and applicants for registration who disagree with a decision made by the Canada Revenue Agency (CRA).
Before you file an objection
If you disagree with a CRA decision issued by the Charities Directorate, we strongly recommend that you first contact the Directorate to discuss the matter.
Sometimes providing missing information, a late return, or a small clarification can solve the issue without the need to file an objection. Many disputes are resolved this way.
Contacting the Charities Directorate is optional. It does not extend the time limit to file an objection. You must still submit your objection within the required timeframe.
Understand the objection process
If you believe the CRA made a mistake in applying the facts or the law, you can file an objection to a notice or an assessment.
The Appeals Branch undertakes formal and impartial reviews of decisions made by other areas of the CRA. It will review your objection and all relevant information before making a final decision.
This process ensures that the CRA applies Canada’s tax laws fairly and consistently.
Who can file an objection and when
Applicants for registration
Your organization may file an objection to a notice of refusal of registration if you are a:
- Canadian amateur athletic association
- Charity
- Journalism organization
- Low-cost housing corporation for the aged
- Municipal or public body performing a government function in Canada
- National arts service organization
Registered charities
Registered charities may file an objection to a notice of:
- Annulment of registration
- Assessment of penalty
- Denial of redesignation
- Intention to revoke registration
- Suspension of tax-receipting privileges
Registered national arts service organizations
Registered national arts service organizations may file an objection to a notice of:
- Annulment of registration
- Assessment of penalty
- Intention to revoke registration
- Suspension of tax-receipting privileges
Revoked charities and revoked national arts service organizations
Revoked charities and revoked national arts service organizations may file an objection to a notice of:
- Assessment of penalty
- Assessment of revocation tax
Other qualified donees
Registered Canadian amateur athletic associations and registered journalism organizations, may file an objection to a notice of:
- Assessment of penalty
- Intention to revoke registration
- Suspension of tax-receipting privileges
Registered Canadian municipalities, registered foreign charities that received a gift from His Majesty in right of Canada, registered low-cost housing corporations for the aged, registered municipal or public bodies performing a function of government in Canada, and registered universities outside Canada may file an objection to a notice of:
- Intention to revoke registration
- Suspension of tax-receipting privileges
File an objection
Who is authorized to file
Only members of the organization’s board of directors or an authorized representative may file an objection. Objections submitted by unauthorized individuals will not be accepted.
To ensure your charity account is managed effectively, make sure to authorize the relevant people and keep the list up to date. For more information, go to Manage who can access your charity account.
If you require assistance or more information, contact the Charities Directorate.
Filing deadline
You must file your objection within 90 days of the date shown on the notice or the assessment.
Requesting extra time to file an objection
If you cannot file your objection on time because you tried to resolve the issue with the CRA or due to circumstances beyond your control, you may request a time extension. You can do this when you submit your objection.
To request an extension:
- Explain the facts and reasons why you did not file on time, and include your objection.
- Apply as soon as possible, but no later than one year after the original filing deadline.
You must show that:
- You could not file the objection (or have someone file for you) within the objection period, or you intended to file;
- It would be fair to grant your request; and
- You applied as soon as you could.
We will notify you in writing of our decision. If granted, your objection is considered filed on the date the extension decision is sent.
What to include
Your objection should include:
- Your organization’s name and complete mailing address
- Your organization’s 15-digit business number
- Your name and daytime telephone number
- The date of your notice or assessment
- The tax year of the assessment (if applicable)
- The name and address of your authorized representative (if applicable)
- The reasons you disagree with the CRA’s decision
- All relevant facts and supporting documents
Including all required information and documents helps us reduce delays in the review of your objection.
If you provide information that was not submitted during an audit or a previous CRA request, it may be sent back to the Charities Directorate for review.
How to send your objection
Through your CRA account
If your organization has an RR account (charity account number) and is a registered charity, registered Canadian amateur athletic association, or registered national arts service organization, you can file an objection through your CRA account using the File a formal dispute function.
Sign in to your CRA account to access My Business Account if you are filing for your organization or Represent a Client if you are an authorized representative.
After submitting, you will receive a case number. Use this number to upload any supporting documents through the Submit documents function.
If you need help accessing the CRA’s online services, go to Register to use online services for charities.
By fax
1-888-329-9404
By mail
Mail may delay processing. We recommend using your CRA account or fax whenever possible.
Assistant Commissioner
Appeals Intake Centre
Post Office Box 2006, Station Main
Newmarket ON L3Y 0E9
Appeal a decision in court
If you disagree with the CRA’s final decision on your objection, you may appeal to the appropriate court. Court appeals are separate from the objection process. They also have their own deadlines.
Where to appeal and deadlines
Appeal to the Federal Court of Appeal within 30 days from the date of the CRA’s notice for decisions related to an objection to:
- Annulment of registration
- Denial of redesignation
- Intention to revoke registration
- Refusal of registration
Appeal to the Tax Court of Canada within 90 days from the date of the CRA’s notice for decisions related to an objection to:
- Assessment of penalty
- Assessment of revocation tax
- Suspension of tax-receipting privileges
Decisions of the Tax Court of Canada can be appealed to the Federal Court of Appeal. Decisions of the Federal Court of Appeal can be appealed to the Supreme Court of Canada, with permission.
If you need more information
For general questions about the objection process, leave a voicemail at 613-670-7348. We will call back within two business days.
We cannot give legal advice or comment on the merits of your situation.