Receiving a CRA reassessment that you believe is incorrect is not the end of the road — it is the beginning of a formal dispute process that gives you real rights to challenge CRA's position. Filing a Notice of Objection is the first and most important step, and doing it correctly — on time, in writing, with the right arguments — sets up the best possible outcome. This guide walks through the full process, from reviewing the reassessment to potential Tax Court appeal.
Before filing an objection, read the Notice of Reassessment and any attached audit report carefully. Identify exactly which items are being changed and the CRA position on each. Not every item in a reassessment may be wrong — your objection should focus on the specific items you dispute, supported by your reasons and evidence. A well-focused objection is more effective than a general dispute of everything.
Gather all supporting documentation for your position: receipts, contracts, banking records, professional advice, prior-year filings. The earlier you compile this material, the stronger your objection file will be.
A Notice of Objection can be filed on Form T400A (for individuals) or by letter. It must:
The objection can be filed by mail to the Chief of Appeals at your Tax Centre, or electronically through My Account or My Business Account. CRA will acknowledge receipt and assign an appeals officer to the file. Processing times currently range from several months to over two years depending on complexity and CRA workload.
Interest on disputed tax amounts continues to accrue during the objection process. If your dispute involves a substantial amount and the objection process may take years, consider paying the disputed amount under protest to stop interest from running. CRA will refund the amount plus refund interest if the objection succeeds. The current CRA prescribed interest rate on overdue tax is set quarterly and is meaningfully higher than savings account rates.
After filing, CRA Appeals will assign a dedicated appeals officer to your file. This officer is independent from the audit team — they review the file fresh. The process typically involves:
| Outcome | What Happens |
|---|---|
| Vacated | Assessment fully reversed — CRA withdraws the reassessment |
| Varied | Assessment partially adjusted — settlement |
| Confirmed | CRA upholds the original assessment — Tax Court is next |
CRA Appeals officers have authority to settle disputes without going to Tax Court. Settlements are common where the facts support some but not all of the assessment, where legal uncertainty exists, or where the cost of litigation exceeds the disputed amount. Approach settlement discussions with clear, organized evidence and a realistic assessment of the merits of each disputed item.
If the appeals officer confirms the assessment and you disagree, you have 90 days from the date of the Confirmation Letter to file an appeal with the Tax Court of Canada. The Tax Court has exclusive jurisdiction over income tax disputes. For amounts under $25,000 in tax and penalties, the Informal Procedure applies. For larger amounts, the General Procedure — a full litigation proceeding — applies.
Professional representation during a tax objection significantly improves outcomes. A tax professional can review the reassessment, identify which items have the strongest legal basis for dispute, organize the evidence, and present the arguments persuasively to the appeals officer. Our tax team handles CRA objections and appeals for clients across all industries. Contact us as soon as you receive a reassessment you disagree with — timing is critical.