A reassessment from CRA can take you by surprise. You filed your return months ago, the original assessment looked correct, and now CRA is saying you owe additional tax. Often the reassessment is wrong. The Notice of Objection is your formal right under the Income Tax Act to dispute that position. It is also a strict-deadline process that closes permanently if you miss it. This guide walks Calgary taxpayers through every stage from the moment the reassessment arrives to the final resolution.
What a Notice of Objection Is
A Notice of Objection is a written submission to CRA stating that you disagree with a specific assessment or reassessment and explaining why. Filing the objection formally engages CRA's Appeals Division, which is an independent group within CRA whose role is to review disputed assessments from a neutral position. The Appeals Division reviews the file, requests additional information if needed, and issues either a confirmation (the reassessment stands), a variation (partial change), or a vacating (the reassessment is reversed). It is the gateway to all subsequent appeal rights, including the Tax Court of Canada.
The 90-Day Deadline
You have 90 days from the date of the reassessment to file a Notice of Objection. This deadline is strict. The 90 days runs from the date printed on the reassessment, not the date you received it or noticed it in your CRA My Account inbox. If you miss the 90-day window, the only option is to apply for an extension under section 166.1 of the Income Tax Act, which CRA may grant for up to one additional year if you can demonstrate that you could not file on time due to extraordinary circumstances. Extensions are not guaranteed. Missing the original deadline often means losing the dispute right entirely. Mark the date the moment the reassessment arrives.
When to File an Objection vs. Other Options
Not every CRA decision requires a formal objection. If the reassessment is the result of a clerical error or missing information that you can simply provide, a phone call to the CRA agent identified on the letter may resolve it informally. If the issue is a misinterpretation of facts or law, or if you have already tried the informal route and been refused, a formal objection is the right path. If the dollar amount is small (under $25,000 for individuals) and you do not need the appeal court option, sometimes a request to the original assessor for adjustment is the fastest route. A CPA can evaluate the situation in fifteen minutes and tell you which path makes sense.
What to Include in the Objection
A formal Notice of Objection is submitted on Form T400A (for individuals) or T401 (for corporations), or through CRA My Account. The submission must include the tax year, the date and reference number of the assessment being objected to, the specific issues in dispute (every item you disagree with should be listed), the facts supporting your position, the law or policy supporting your position (relevant Income Tax Act sections, jurisprudence, CRA folios), and the relief requested. Vague objections fail. A specific, well-documented objection that cites authority is dramatically more likely to succeed.
Large Corporations and Special Rules
If your corporation is a Large Corporation under the Income Tax Act (taxable capital employed in Canada exceeding $10 million), additional rules apply. The Notice of Objection must specify each issue, the relief sought, and the facts and reasons supporting the position with much greater specificity than for individuals or smaller corporations. Issues not raised in the objection cannot generally be raised at the Tax Court of Canada level later. Large Corporation objections require careful preparation and often involve both a CPA and a tax lawyer.
What Happens After You File
After your objection is filed, CRA acknowledges receipt within several weeks. An Appeals Officer is assigned, usually within three to nine months depending on complexity. The officer reviews your submission, the original auditor's working papers, and the underlying tax return. They may contact you or your representative for clarification, additional documents, or a meeting. Throughout this process, collection action on the disputed amount is generally suspended for individuals and small corporations (with limits). The officer eventually issues a decision: confirmation, variation, or vacating of the reassessment. The full process from filing to decision typically takes nine to eighteen months.
Negotiation and Settlement
Most objections settle before a final Appeals decision. The Appeals Officer often proposes a partial adjustment that recognizes part of your position. You can accept the proposed settlement, counter, or decline and proceed to a final adverse decision (which then opens the Tax Court route). Settlement is appropriate when the cost and risk of further appeal outweigh the additional amount in dispute. A CPA represents your interests in these negotiations, often achieving meaningful reductions even when full vacating is not realistic.
If You Disagree With the Appeals Decision
If the Appeals Division confirms the reassessment in whole or in part and you still disagree, you have 90 days from the date of the Appeals decision to file an appeal with the Tax Court of Canada. The Tax Court has two procedures: informal (for disputes under $25,000 per year for individuals or $50,000 federal tax for corporations) and general. Informal procedure is faster, less expensive, and does not require a lawyer (though one is often used). General procedure follows formal court rules and almost always involves a tax lawyer. A CPA prepares the underlying tax analysis. A tax lawyer presents the case in court.
Interest During the Objection
Interest continues to accrue on the disputed amount throughout the objection process. If you ultimately lose the objection, you owe the original tax plus all interest that has accumulated. This is one reason objections should not be filed simply to delay payment. If you are confident the reassessment is wrong, pursuing the objection is correct because the interest cost is small relative to the tax saved if you win. If your position is weak, paying the assessed amount and ending the interest meter may be smarter than fighting a likely-losing battle. A CPA helps assess the strength of your position before you commit.
Common Mistakes to Avoid
Filing the objection without supporting documentation. Failing to identify every disputed issue (issues not raised cannot generally be added later). Missing the 90-day deadline. Filing a vague or emotional objection that does not cite legal authority. Trying to handle a complex objection without professional help. Continuing to argue facts after they have been settled, rather than challenging the legal interpretation. Settling for less than the case is worth, or pushing further than the evidence supports. Each of these mistakes is common and avoidable with proper preparation.
Working With a CPA on Your Objection
At Finsight Accounting we represent Calgary taxpayers throughout the objection process. Our role includes reviewing the reassessment for errors, identifying every dispute issue with merit, drafting the formal objection with citations to relevant authority, responding to CRA Appeals Officer requests, negotiating settlements, and advising on whether to proceed to Tax Court if the outcome is unfavourable. The cost of representation is typically a small fraction of the tax at stake and consistently produces better outcomes than self-represented objections.
Frequently Asked Questions
Finsight Accounting CPA
This article was prepared by the CPA team at Finsight Accounting Professional Corporation, a licensed CPA firm based in Calgary, AB. Content is for general information purposes only and does not constitute professional tax advice. Consult a CPA for advice specific to your situation.