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
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
Written by
Julian Fraser
WealthNorth