Resolving disputes

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

If you are not satisfied with the answer after talking to the Canada Revenue Agency (CRA), 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 the CRA has 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 file an objection:

• online, using the "File a formal dispute (Notice of Objection)" service at:
  • Represent a client, if you are an authorized representative or employee
  • My Business Account, if you are a business owner
• by mail, using Form T400A, Notice of Objection – Income Tax Act, or writing to the chief of appeals at your Appeals Intake Centre (see Appendix B of Guide P148) to find out the appropriate centre)

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

Notice of objection requirements for large corporations

For large corporations, the notice of objection has to:

• reasonably describe each issue
• specify for each issue 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 balance of unclaimed outlays, expenses, or other amounts of the corporation
• provide facts and reasons the corporation relied on for each issue

How objections are processed

Once the CRA receives 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 the CRA 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 Guide 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.

Forms and publications

• Guide T4012, T2 Corporation – Income Tax Guide
• Guide P148, Resolving Your Dispute: Objections and appeal rights under the Income Tax Act
• Form T400A, Notice of Objection – Income Tax Act

Related topics

• Objections, appeals, disputes, and relief measures