Resolving disputes

If you disagree with the notice of assessment you receive, contact us.

If you are not satisfied with our answer after talking to us, you have the right to make a formal objection.

You can make a formal objection if you disagree with the amount of tax, interest, or penalties we have assessed or reassessed.

You have 90 days from the date of the notice of assessment, or reassessment, to file the objection.

Making a formal objection

You can make an objection:

You must explain the reasons for the objection and outline all the relevant facts. 

Note

Appealing a loss has a different formal objection process because there is no tax, interest, or penalty involved. See Disputing loss determinations for more information.

Notice of objection requirements for large corporations

For a large corporation, the notice of objection has to:

  • reasonably describe each issue
  • specify the relief you are seeking, expressed as the amount of a change in the income, taxable income, loss, taxes payable, refundable amounts, and overpayments or a balance of unclaimed outlays, expenses, or other amounts of the corporation
  • provide facts and reasons the corporation relied on for each issue

Note

A corporation is a large corporation if the total taxable capital employed in Canada at the end of the tax year by the corporation and its related corporations is over $10 million.

How objections are processed

Once we receive the objection, an appeals officer at the Appeals Intake Centre will review the assessment or reassessment in dispute. The appeals officer will then contact the corporation or its authorized representative to discuss the differences and to try to resolve the dispute.

If the differences in how we interpreted or applied the law are not resolved, the corporation can then appeal the assessment or reassessment to the Tax Court of Canada.

Payment of disputed amounts

You do not have to pay the disputed amount of tax, interest, or penalty while you are waiting for the outcome of the CRA's or the Tax Court of Canada's review. However, once the objection or appeal is settled, normal interest charges will apply to any tax, interest, or penalties outstanding. Interest charges are calculated from the balance-due day.

For more information, see Pamphlet P148, Resolving Your Dispute: Objections and Appeal Rights under the Income Tax Act.

Payment of disputed amounts for large corporations

A large corporation that objects to an assessment will have to pay 50% of the disputed amount. The corporation also has to pay the full amount of taxes not in dispute.

The Income Tax Act describes specific requirements for large corporations.

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