CRA Notice of Objection: Deadlines, Filing Steps and What Happens Next

Is an objection the right route?

A formal objection is for a dispute about an assessment, reassessment or determination under the Income Tax Act. You may think CRA misunderstood facts or applied the law incorrectly. CRA Appeals reviews a valid objection separately from the original assessment area.

First read the explanation on your notice of reassessment. If you forgot a slip or entered an amount incorrectly, CRA may direct you to change your tax return. If your information is complete and you disagree with CRA’s result, the objection path is more likely relevant. Asking a question or submitting a correction does not automatically protect an objection deadline.

Not every account item can be objected to. CRA’s P148 guide lists examples such as an RRSP or TFSA room statement, carryforward balance or statement of account. The assessment of a penalty or interest can be different. If the document is not clearly an assessment or determination, check CRA’s income-tax objection decision tree.

How do you work out the deadline?

For an individual other than a trust, and for a graduated rate estate, CRA’s P148 guide says the income-tax objection deadline is whichever of these two dates is later:

1. One year after the filing deadline for the return; or
2. 90 days after the date of the assessment or determination notice.

For other cases, including a loss determination or tax assessed for excess RRSP or TFSA contributions, P148 says the deadline is generally 90 days from the notice. Corporations also have a 90-day rule. Do not borrow the ordinary individual rule for a different type of notice. Check the actual tax year and notice date, and use the official guide when working out the deadline.

If the deadline has passed, CRA may consider a request for an extension. P148 says to apply as soon as possible and no later than one year after the original objection deadline. You need to explain why you did not file on time and provide the objection. An extension is not automatic. When a deadline is close, get help with the specific dates rather than relying on a rough example.

How can you file?

CRA’s secure portals let an individual select Register my formal dispute in My Account. The portal gives a case number. An authorized representative can use Represent a Client. CRA also accepts a completed T400A income-tax objection form by mail or fax, or a signed letter clearly setting out the facts and reasons. Check the current P148 guide for the Appeals Intake Centre address or fax details.

Use the income-tax route for an Income Tax Act objection. A GST/HST objection has a separate process and form. If several assessments are disputed, CRA says separate notices may be needed, although its online process can submit more than one at once. Make the document and tax year explicit.

What information should you include?

A short explanation is more useful when each disputed item is tied to evidence. CRA lists the following for an objection:

• Your name, mailing address and daytime phone number.
• The notice date, tax year and relevant account number.
• The precise item or amount you dispute and the facts and reasons for your position.
• Copies of documents that support those facts.
• Details of an authorized representative, if one is acting for you.
• Your signature and date for a paper objection.

Include a copy of the notice with a paper filing. Keep the originals of supporting documents and a copy of what you sent. If you file online, keep the case number and use it when submitting documents later. Avoid sending personal account details to CMH; send the objection only through CRA’s official channels.

What happens after CRA receives it?

CRA checks whether the objection is valid, assigns a case number and may ask for more information. An appeals officer reviews the facts and the assessment. The result may confirm CRA’s decision or change it in whole or part. An invalid objection receives an explanation. There is no reliable processing time that covers every case; missing documents and complexity can add time.

If CRA issues a new reassessment while an objection is underway, its P148 guide says the original objection is cancelled and a new objection can be filed against the new reassessment. Read any new notice carefully rather than assuming the old case covers it.

Does an objection stop payment or interest?

For many disputed income-tax amounts, CRA normally postpones collection action while the objection is under review. Important exceptions include some source-deduction matters, amounts considered in jeopardy, certain tax-shelter claims and large corporations. Do not assume the same rule protects a GST/HST debt.

CRA says interest generally continues on an unpaid amount in dispute. Paying all or part can reduce interest; it does not by itself mean you agree with CRA’s assessment. This is a separate decision from filing the objection. Check your own balance and CRA’s collection and payment guidance before assuming you must pay immediately or may ignore the debt.

If CRA does not change the decision

A Tax Court appeal is separate from the CRA objection review. P148 explains the appeal route and the time limit after an objection decision. Because court procedure and exceptions matter, use CRA’s current court-appeal guidance and consider qualified advice before filing. Do not treat a second phone call as a court appeal.

CRA’s P148 guide says an income-tax appeal may be filed within 90 days after CRA mails or electronically sends its objection decision. It also describes an appeal route if 90 days have passed since you filed the objection without a CRA decision. These are different starting points: keep both your objection filing confirmation and any decision notice, then check the court’s current filing requirements.

Common mistakes

• Using 90 days for every individual return: The ordinary individual income-tax rule compares two dates.
• Waiting for a correction request: It does not automatically extend an objection deadline.
• Assuming a late extension will be granted: CRA applies conditions and a separate one-year limit.
• Sending a bare statement of disagreement: Identify the disputed item, facts, reasons and documents.
• Mixing income-tax and GST/HST routes: Their forms and collection rules can differ.