A CRA notice of objection is your formal, written disagreement with an assessment, reassessment or determination that is correct on the facts you filed. It starts an independent review by the CRA Appeals Branch and, if you still disagree, opens the door to the Tax Court of Canada. Two features make this process unforgiving: the deadlines are fixed in the Income Tax Act, and collection of disputed amounts may be postponed only in some cases. This guide sets out who can object, how to file, what to include and what happens next.
How to file a CRA notice of objection
- Confirm that objection is the right tool. If you left something out or entered it incorrectly, change the return instead. If your information is complete but you disagree with the assessment or reassessment, object. See notice of assessment and reassessment.
- Check the time limit. Count from the date on the notice, not the day you opened it. Loss determinations and RRSP or TFSA over-contribution assessments must be objected to within 90 days.
- Choose the method. Online, log in to your CRA account (My Business Account for businesses) and select Register my formal dispute. You will receive a case number. Representatives use Represent a Client. By paper, complete Form T400A or write a signed letter setting out the facts and reasons, and send it to the Chief of Appeals at your Appeals Intake Centre. The CRA notes that a secure portal gets your objection to an appeals officer sooner.
- Include the required details. Your name, mailing address and daytime phone number; the notice date and tax year; your SIN, business number or account number; the facts and reasons for the objection; copies of supporting documents; and your representative's name and address, if any. The objection must be signed and dated, and an authorized officer must sign for a corporation. File a separate objection for each assessment unless the facts and reasons are identical, and include a copy of the notice with paper filings.
- Quote the case number. The CRA tells you to use it in all correspondence. If the objection is not valid, the CRA writes to explain why.
What are the deadlines?
| Step | Deadline as published (2026) |
|---|---|
| Objection, individual (not a trust) | Later of one year after the return's filing deadline, or 90 days from the notice date |
| Objection, loss determination or RRSP/TFSA over-contribution assessment | 90 days |
| Objection, corporation | 90 days from the notice date |
| Extension of time to object | Apply as soon as possible and no later than one year after the date you had to object |
| Appeal to the Tax Court of Canada | 90 days from the notice of confirmation, reassessment or redetermination, or after 90 days with no decision on the objection |
| Extension of time to appeal | Apply within one year and 90 days from the date of confirmation, reassessment or redetermination |
| Federal Court of Appeal | Within 30 days of the Tax Court's final judgment (July and August excluded) |
| Supreme Court of Canada | Leave application within 60 days of the Federal Court of Appeal judgment (July excluded) |
The CRA's notice of assessment page summarizes the individual rule as 90 days from the date of the notice. Work from 90 days unless your Canadian CPA confirms a later date applies. For an extension you must show that you could not object, or intended to object, within the period, that granting the extension would be fair, and that you applied as soon as you could. If it is granted, the objection is treated as filed on the date of the extension decision notice. If it is refused, or no decision is made within 90 days, you can apply to the Tax Court.
What happens after you file?
The Appeals Branch reviews the objection impartially and may contact you or your representative. You may request documents such as your returns, auditor reports and working papers, though some information, including third-party confidential information and solicitor-client privileged material, cannot be provided. If the CRA agrees in whole or in part, it issues a notice of reassessment or redetermination. If it disagrees, it issues a notice confirming the original assessment. If you receive a new reassessment after objecting, the original objection is cancelled and you can object to the new one.
How does the Tax Court of Canada appeal work?
You file a notice of appeal by mailing or delivering it to a Tax Court of Canada office, by fax, or through the Court's electronic filing. There are two procedures. The informal procedure carries no filing fee. Under the Tax Court of Canada Act, it is available for income tax appeals where the aggregate of all amounts in issue is equal to or less than $25,000, or the loss in issue is equal to or less than $50,000. The general procedure carries a filing fee based on the amount in dispute; the Court publishes the amounts. The Act is the source for these thresholds, so confirm them with your lawyer before electing a procedure.
Collection while the dispute is open
For objections, the CRA says collection is normally postponed until 90 days after it sends its decision, but not in some cases, such as taxes you were required to withhold and remit, or amounts in jeopardy. Large corporations must pay 50 percent of the disputed amount when filing. Interest generally still applies, and a partial payment reduces it. If you appeal to the Tax Court, the CRA normally postpones collection until the court mails its decision or you withdraw. The Taxpayer Bill of Rights includes the right not to pay personal tax amounts in dispute until an impartial review. See CRA collections.
What you cannot object to
Penalty and interest relief is a separate request, not an objection; see CRA penalties and interest. The Voluntary Disclosures Program has its own review route, since there is no objection right to a decision there. A waiver you signed in an audit also ends objection rights on the waived issues; see CRA audits.
How the other countries compare
| Authority | First review | Next step | Reading |
|---|---|---|---|
| CRA | Notice of objection, Appeals Branch | Tax Court of Canada within 90 days | This page |
| IRS | Appeals through a protest or small case request | Tax Court petition within 90 days (150 outside the US) after a notice of deficiency | IRS audit types |
| India | Appeal to the Commissioner (Appeals) | Appellate tribunal | India appeals |
A worked example
Karan lives in Calgary and receives a notice of reassessment dated September 15, 2026 for 2022, which disallows $6,000 of employment expenses. The filing deadline for 2022 was April 30, 2023, so the one-year rule has already passed; 90 days from the notice date is December 14, 2026. His Canadian CPA files the objection online in October with the employer's expense statement, receipts and mileage records. The CRA confirms the reassessment by notice dated February 24, 2027, so the 90-day Tax Court period runs to May 25, 2027. The amount in issue is under $25,000, so the informal procedure is possible. Dates and amounts are hypothetical.
Mistakes to avoid
- Counting from the day you opened the notice instead of the date on it.
- Objecting when you should file a change request.
- Filing a combined objection for different assessments with different facts.
- Skipping supporting documents.
- Missing the 90-day Tax Court period after a confirmation.
How we can help
We do not represent clients before the CRA or the Tax Court of Canada. Your Canadian CPA or tax lawyer manages the objection and appeal. From our Aurora, Illinois area base, we handle the U.S. effects of the outcome, such as changes to foreign tax credits or amended US returns, and we coordinate timing with your Canadian professional. We cannot guarantee a result. See cross-border tax. Browse the notices hub for every guide in this series.
Frequently asked questions
How long do I have to file a notice of objection?
For individuals, the later of one year after the filing deadline or 90 days from the notice date; for corporations, 90 days.
Can I object late?
You can apply for an extension, as soon as possible and no later than one year after the date you had to object, if you meet the fairness tests.
Do I have to pay while I object?
Collection is normally postponed for disputed amounts in many cases, but interest generally continues and some amounts are not covered.
Can I appeal if the CRA does not answer?
Yes. For income tax you may appeal to the Tax Court of Canada if the CRA has not decided within 90 days of your objection.
Do I need a lawyer for the Tax Court?
Not always. The informal procedure is designed for simpler cases, but get advice on which procedure fits.
Official sources
- CRA: Resolving your dispute, objection rights under the Income Tax Act (P148)
- CRA: File an appeal to the Court, income tax or GST/HST
- Justice Laws: Tax Court of Canada Act
- CRA: Notice of assessment, understand your NOA
- CRA: Taxpayer Bill of Rights
This page summarizes public guidance in plain language. If anything here differs from the official source, the official source controls.
General information only. It is not tax, legal, accounting or immigration advice for your situation, and rules change; confirm the current rules with the official source or a licensed professional in the relevant country.