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How to Appeal a CRA Reassessment Canada 2026

Updated

Understanding Reassessments

Types of CRA Adjustments

Type What It Means
Reassessment CRA changed your return
Adjustment You requested a change
Audit assessment Result of review/audit
Arbitrary assessment CRA filed for you

Common Reassessment Reasons

Reason Example
Disallowed deduction RRSP over-contribution
Income addition Unreported T4/T5
Credits denied DTC not approved
Audit adjustment Business expenses disallowed
Error correction Math mistakes

The Appeal Process

Three Levels of Dispute

Level Timeline Cost
1. Notice of Objection 90 days to file Free
2. Tax Court of Canada 90 days after CRA decision Varies
3. Federal Court of Appeal 30 days after Tax Court Higher

Level 1: Notice of Objection

Deadline

Situation Deadline
Standard 90 days from reassessment date
Extension Up to 1 year from deadline
Extension requirements Reasonable grounds, file within 1 year

How to File

Method Details
Online CRA My Account β†’ Register a dispute
Mail Form T400A or letter to Tax Centre
Fax To Appeals Intake Centre
In person At tax services office

What to Include

Element Details
Tax year(s) Which years disputed
Issues What CRA got wrong
Facts Your version of events
Legal grounds Tax law supporting you
Documents Receipts, statements, etc.
Relief requested What you want

Sample Objection Letter

[Your Name]
[Address]
[SIN]
[Date]

CRA Appeals Division
[Address]

Re: Notice of Objection - [Tax Year]

I am filing this objection to the Notice of Reassessment 
dated [date] for the [year] taxation year.

Issue: [Describe what CRA changed]

Facts: [Explain what actually happened]

Position: [Why you disagree with CRA]

Supporting Documents: [List attachments]

Relief Requested: [What you want - reversal, adjustment]

Sincerely,
[Your name]

What Happens After Filing

CRA Appeals Process

Stage Timeline
Acknowledgement 2-4 weeks
Assigned to officer 1-6 months
Review 3-12+ months
Decision Notice of Confirmation or reassessment

Possible Outcomes

Outcome Meaning
Allowed in full You win completely
Allowed in part Partial victory
Confirmed CRA stands by reassessment
Varied Different adjustment

Level 2: Tax Court of Canada

When to Go to Court

Situation Consider Court
CRA confirmed objection Next step
CRA took 90+ days Can appeal directly
Strong case Worth pursuing
Significant amount Justifies cost

Time Limit

Trigger Deadline
Notice of Confirmation 90 days to appeal
CRA didn’t respond (90+ days) Anytime after

Court Procedures

Procedure Amount Details
Informal Under $25,000/year Simpler, no lawyers needed
General Over $25,000/year Formal, usually need lawyer

Informal Procedure

Feature Details
Cost $100 filing fee
Representation Self, accountant, or lawyer
Rules Simplified
Evidence More flexible
Time Faster resolution

Collections During Dispute

Requesting Collections Hold

Rule Details
Automatic hold Collections paused during objection
Court appeal May need to request hold
Interest Continues to accrue
Security CRA may require

Paying While Disputing

Option Consideration
Pay in full Refunded if you win, with interest
Pay nothing Collections held but interest accrues
Pay partial Reduce interest accumulation

Tips for Success

Building Your Case

Tip Why
Gather all documents Prove your position
Be detailed Explain clearly
Cite tax law Strengthen argument
Organize chronologically Easy to follow
Get professional help If complex

Common Mistakes

Mistake Impact
Missing deadline Lose appeal right
Vague objection Weak case
No documents Can’t prove claims
Emotional language Unprofessional
Wrong form/process Delays

When to Get Help

Consider a Professional

Situation Recommended
Large amounts Yes
Complex issues Yes
Business matters Yes
Simple errors Maybe self-file
Audit-related Yes

Who Can Help

Professional Best For
Accountant (CPA) Tax calculations, basic disputes
Tax lawyer Complex legal issues, court
Tax specialist Specific expertise

Cost Considerations

Service Typical Cost
Accountant review $200-$1,000
Objection assistance $500-$3,000
Tax Court (informal) $2,000-$10,000+
Tax Court (general) $10,000-$50,000+

Taxpayer Bill of Rights

Your Rights

Right Protection
Be treated professionally Respect and courtesy
Privacy Information confidential
Complete information Know your obligations
Fair application Consistent interpretation
Appeal Formal dispute mechanism

Taxpayer Ombudsman

When to Contact Issue
Service complaints Not audit disputes
Process delays Unresponsive CRA
Conduct issues CRA behavior