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Tax Brief: CRA Disputes

When a federal tax return is issued a Notice of Assessment, taxpayers may sometimes find themselves disagreeing with the assessment (or reassessment) and tax, interest and/or penalty. In order to dispute/clear up the issues at hand, the taxpayer has the opportunity to resolve the issue(s) with the tax centre that processed the return and if that method is still unsatisfactory, the taxpayer can serve a notice of objection to the Minister.

Amounts owing/in dispute

Assessment/reassessment disputes may go on for while, as the CRA reviews all necessary information related to the appeal. While the appeal is being reviewed, interest will continue to accrue on any amounts owing to the CRA. As such, if the taxpayer can afford to pay amounts owing, this will (1) stop any late interest from accruing and (2) if upon successful appeal, they'll receive a refund with interest.

When can one dispute

Generally, there are no restrictions on objections, other than when a taxpayer has waived the right to object or when an assessment is issued under the Taxpayer Relief Program.

If a taxpayer is filing an objection, the objection must be made by:

- Individuals and graduated rates estates: the later of (1) one year after the "filing due date" and (2) 90 days after the date on the Notice of Assessment

- Other cases: 90 days after the date on the Notice of Assessment

How long until I hear back

Although no fixed time limit on when the Minister must respond to an objection, if 90 days have passed since the objection has been filed, with no response from the Minister, the taxpayer may appeal directly to the Tax Court of Canada


Questions in how the above matter may relate to you? Reach out to Blumenfeld Woznica & Co to see how this matter may impact your specific accounting and/or tax situation.


This publication is provided as an information service and may include items reported from other sources. We do not warrant its accuracy. This information is not meant as account/tax opinion or advice.

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