Do you have unfiled taxes? Do you have problems with CRA?

TLDR:

You have 90 days from the date on your Notice of Assessment or Reassessment to file a Notice of Objection or, for individuals, one year after your filing deadline, whichever is later. You can file your Notice of Objection through your CRA My Account (“Register My Formal Dispute”), or by mailing Form T400A (income tax) or Form GST159 (GST/HST).

A CRA Notice of Reassessment lands in your inbox, and suddenly you owe thousands more than you expected. Most people’s first instinct is to call the CRA and explain why the CRA’s assessment is wrong. That conversation might help, but it doesn’t protect your legal rights. Only a Notice of Objection does that.

What Is a Notice of Objection?

A Notice of Objection is a formal request for CRA’s Appeals Division, a separate branch from the auditor or assessor who issued your reassessment to independently review your file.

It’s the first step in disputing almost any CRA decision, and it’s a legal prerequisite: you generally cannot go to the Tax Court of Canada without filing one first.

You can object when CRA has:

• Disallowed expenses or deductions you believe were legitimate
• Reclassified income (e.g., taxing a property sale as business income instead of a capital gain)
• Changed your marital status and adjusted related credits
• Denied Input Tax Credits (ITCs) on a GST/HST reassessment
• Applied penalties following an audit
• Reassessed rental or self-employment income

The 90-Day Clock: CRA Objection Deadlines

This is the number that matters most, and the one people get wrong most often.

Individuals (excluding trusts) have until the later of:

• One year after the filing deadline for the return, or
• 90 days from the date on the Notice of Assessment or Determination

Corporations, trusts, and everyone else (including loss determinations) get a flat 90 days from the date on the notice. There is no “one year” fallback.

Filing is done through CRA My Account or My Business Account (“Register My Formal Dispute”), by mailing Form T400A (income tax) or Form GST159 (GST/HST), or by fax.

Filing through your CRA My Account is generally the fastest and gives you a receipt confirming the date CRA received it.

One interesting note: For income tax debts, filing an objection generally pauses CRA collections action on the disputed amount. It does not pause collections for GST/HST or payroll balances, and interest keeps accruing on income tax debts either way even while collections is paused.

Notice of Objection vs. Tax Payer Relief

An objection isn’t always the right tool. Here’s how it stacks up against the Tax payer relief covered in our blog post here.

Missed the Deadline? You May Still Have a Window

If the 90 days has already passed, you’re not automatically out of options. You can apply for an extension of time to object, but the request must be made within one year of the original deadline, after that, the door closes for good.

To succeed, you generally need to show:

• You intended to object, or genuinely couldn’t, within the original 90 days
• It would be fair and reasonable to grant the extension
• You applied for the extension as soon as you were reasonably able to

Extensions are not automatic. The CRA reviews the facts of each request, so the explanation and supporting documentation matter as much as the request itself.

What Happens After You File

Once CRA logs your objection, an independent Appeals Officer, someone with no involvement in the original assessment is assigned to review the facts, the law, and your supporting documents. They may contact you or your representative for more information before making a decision.

The officer will ultimately do one of three things:

• Vacate the assessment (cancel it entirely)
• Vary it (adjust it in your favour, in whole or in part)
• Confirm it (no change)

How long does this actually take? Based on CRA’s most recently published data, average resolution times by complexity are running roughly:

• Low complexity (e.g., individual credits, personal deductions): ~4 months
• Medium complexity (e.g., business expenses, small corporation issues): ~12 months
• High complexity (e.g., multi-year audits, technical interpretation disputes): well over a year, sometimes multiple years

CRA has publicly acknowledged that objection volumes have outpaced its Appeals Division’s capacity, so these timelines have been trending longer, not shorter. If your case sits for an unusually long time, you have an escalation option: if CRA hasn’t responded within 90 days (income tax) or 180 days (GST/HST) of your objection, you can appeal directly to the Tax Court of Canada without waiting any longer.

Common Mistakes That Sink an Objection

• Filing a one-line objection. CRA’s form technically only asks for “the reasons and relevant facts,” and some people take that literally. A thin objection that gets confirmed can be hard to build on later. CRA’s lawyers may argue at Tax Court that an issue was never properly raised at the objection stage.
• Missing the deadline because they were “still gathering documents.” File on time with what you have, and supplement afterward. Appeals accepts additional information after filing.
• Treating it as a form-filling exercise instead of a written case. Facts, documents, and legal references, presented clearly, are what actually sway an Appeals Officer.

FAQs: CRA Notice of Objection

How do I file a Notice of Objection in Canada?

Through CRA My Account or My Business Account (“Register My Formal Dispute”), or by mailing Form T400A (income tax) or Form GST159 (GST/HST) to the Appeals Intake Centre.

Do I have to pay the disputed amount while I object?

For income tax, CRA generally pauses collections on the disputed portion once you file. GST/HST and payroll debts are not paused.

What if CRA confirms the original assessment?

You can appeal to the Tax Court of Canada. There’s generally a 90-day window from the date of the Notice of Confirmation to do so.

Can you help if I already missed the 90-day deadline?

Often, yes. We can file an Application for Extension of Time to Object alongside your objection, provided it’s within one year of the original deadline.

Get Help Today

Filing a Notice of Objection is a legal right but a poorly prepared one can cost you the case before it’s even reviewed. At Taxhelp.ca, we build evidence-backed objections designed to hold up to CRA Appeals scrutiny, and we can also request an extension if you’ve missed the 90-day window. Get in touch with us here for a confidential review of your file.

The accounting and tax information provided in this post does not constitute advice and is meant to be for general information purposes only. The information is current as at the date of this post and does not reflect any changes in accounting and/or tax legislation thereafter. Moreover, the information has been prepared without considering your company or personal financial/tax circumstances and/or objectives.