What is the deadline for a corporation to object to a CRA assessment?
Like individuals, Canadian corporations have 90 days from the date of a Notice of Assessment or Notice of Reassessment to file a Notice of Objection under the Income Tax Act. The same 90-day rule applies regardless of whether the taxpayer is an individual or a corporation.
For corporations, objections must be filed with the Chief of Appeals at the relevant CRA tax services office. Large corporations — those with assets exceeding a prescribed threshold — face additional procedural requirements under the Income Tax Act: they must specify each issue in the objection, the relief sought for each issue, and the facts and reasons relevant to each issue. Failure to adequately specify the issues can limit a large corporation's ability to raise new grounds at the Tax Court level.
If a corporation misses the 90-day deadline, it can apply for an extension of time within the following year, subject to the same grounds as individual taxpayers (it was not reasonably possible to file in time, and there was an intention to object). Because corporations often have accounting and legal teams, courts and CRA are sometimes less sympathetic to missed deadlines by corporations than by unrepresented individuals. Calendar the deadline immediately on receiving a reassessment.
Key takeaways
- Corporations have 90 days from the Notice of Assessment or Reassessment to file an objection.
- Large corporations must specify all issues, relief sought, and reasons in the objection.
- Failing to raise an issue in the objection may prevent raising it at Tax Court.
- Apply for an extension immediately if the deadline is missed — courts are less forgiving with represented corporations.