Notice of Objection
Disagree with a CRA Assessment? File a Notice of Objection
If you’ve received a notice of assessment or reassessment from the Canada Revenue Agency (CRA) and don’t agree with it, you have the right to challenge it by filing a notice of objection.
This is your opportunity to stop a tax debt from being enforced and to make your case. A Toronto tax lawyer can help you take control of the objection process and make sure your arguments are legally sound and strategically presented.
Time Limits Matter
You must file a notice of objection within 90 days of the date on your assessment or reassessment.
If you’ve missed the 90-day window, you can apply for an extension of up to one year but don’t delay.
What Happens After You File a Notice of Objection?
Once your objection is submitted, it’s critical to begin building your case. That includes gathering documentation, reviewing the CRA audit, and preparing strong arguments.
We help clients:
- Review CRA audit findings;
- Identify errors and overreach;
- Develop a strategic objection plan; and
- Prepare legal submissions for the appeals officer supported by legal precedent and tailored to your CRA objection.
The Appeals Officer Review
Your file will eventually be assigned to a CRA appeals officer. This is someone separate from the original auditor. The process typically looks like:
- The appeals officer reviews your file and arguments.
- They issue a proposal letter outlining their preliminary decision.
- You have a final opportunity to respond before a decision is made.
The CRA’s final decision may:
- Cancel the assessment or reassessment;
- Vary the amounts owing; or
- Confirm the original assessment (no changes made).
Next Steps: Tax Court of Canada
If you disagree with the outcome of your objection, you have the right to file an appeal with the Tax Court of Canada.
Why Work with Kirshen Tax Law?
We’ve helped hundreds of taxpayers challenge CRA assessments through the objection process. As experienced Toronto tax lawyers, we know how to navigate the objection process from start to finish, ensuring your voice is heard and your rights are protected. At Kirshen Tax Law, we:
- File the objection properly.
- Develop strong legal and factual arguments.
- Handle communication with the appeals officer.
- Push for the best resolution possible.
Proven Results: Notices of Objection
We’ve helped clients successfully challenge CRA reassessments through well-prepared notices of objection. In many cases, we’ve had assessments significantly reduced or entirely withdrawn before reaching Tax Court. Whether it’s a GST/HST reassessment, a gross negligence penalty, or an income tax dispute, we know how to push back and win.
See examples of successful notice of objections results here.
Book a Free Consultation
Received an assessment or reassessment that you want to contest? Contact us today for a free consultation. You’ll speak directly with a Toronto tax lawyer who knows how to build a persuasive Notice of Objection and maximize your chances of success.