When can we reassess your T2 return

There are different time limits for reassessing your T2 return, depending on the type of corporation and the nature of the reassessment.

Normal reassessment period

The normal reassessment period for a T2 return depends on whether or not the corporation was a Canadian-controlled private corporation (CCPC) at the end of the tax year.

We can usually reassess a return for a tax year:

The normal reassessment period can be extended for various reasons.

Extended reassessment period

The normal reassessment period can be extended for an extra three years for several reasons, including any of the following:

Non-resident non-arm's length person (extra six years)

For losses incurred in a particular tax year that ends after February 26, 2018, the reassessment period for a preceding tax year to which those losses are carried back is extended six years beyond the normal reassessment period if both of the following apply:

Provincial income reallocation (extra one year)

If the reassessment results from a provincial income reallocation, the normal reassessment period can be extended for one year from the later of:

"Stop-the-clock" rule for requirements for information and compliance orders

For challenges made after December 13, 2018, a reassessment period of a corporation is extended by the period of time during which the requirement or compliance order is contested. The period generally starts when the corporation challenges the requirement for information or compliance order and ends on the final disposition of the application (including any appeals). 

Since January 1, 2020, the CRA can send requirements for information, including those for foreign-based information, to banks and credit unions electronically, rather than delivering them in person or by registered or certified mail. Written consent of the bank or credit union is required before requirements can be sent electronically.

Unlimited reassessment period

We can reassess a return at any time for any of the following reasons:

Note

If you want to revoke a waiver that was previously filed to extend the normal reassessment period for a certain tax year, file Form T652, Notice of Revocation of Waiver, at your tax services office. The revocation will take effect six months after you file Form T652.

Sale or disposition of real estate

The CRA may at any time reassess an income tax return beyond the normal reassessment period for any of the following reasons:

Under this extended reassessment period, the reassessment is limited to amounts reasonably relating to the unreported or previously unreported disposition of real or immovable property that is capital property of the corporation or partnership, as the case may be.

If the corporation does not report the disposition in its initial return for the tax year, but later amends its return (for example by filing a request for adjustments under subsection 245(6)), the CRA may still make a reassessment outside of the normal reassessment period within three years of the amendment being filed.

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