CRA OBJECTIONS
Notice of Objection Checklist
A well-crafted Notice of Objection can resolve a dispute early or make later litigation more focused. Use this checklist to prepare a stronger, more organized objection.
Mark the deadline on your calendar (and check it twice)
You have 90 days after the date on the assessment or reassessment to file a Notice of Objection. Mark the deadline immediately and confirm the date on the CRA notice. If you miss it, a one-year extension may be available in limited circumstances.
Organize the objection with litigation in mind
Structure your objection clearly: an executive summary of requested adjustments, a precise list of issues, a chronological statement of facts, law and analysis for each issue, and well-organized appendixes of supporting documents.
Review supporting documents carefully
Be selective. Ensure documents are consistent with what you provided during the audit, and consider how each one could be used against you. Additional documents can usually be submitted later if needed.
Preserve alternative arguments
Lead with your strongest primary position, but keep a reasonable alternative in reserve. For most taxpayers, additional arguments can still be raised later in the objection stage or on appeal to the Tax Court of Canada.
Keep the tone measured and the language simple
Write plainly and directly. Avoid emotional or argumentative language. A professional, credible tone strengthens your position with the Appeals officer.
Consider enhanced requirements for large corporations
Large corporations and specified persons must clearly identify each issue, the relief sought, and supporting facts and reasons. The Tax Court generally cannot hear issues not properly raised in the Notice of Objection.
Calibrate disclosure for large ITA files
In complex corporate files, balance completeness against revealing every possible reassessment position. The minister can sometimes raise alternative bases, but the rules differ between income tax and GST/HST.
Coordinate internally
A tax dispute can affect financial reporting and disclosures. Make sure your tax, finance, and external advisers are aligned before documents are filed.
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