What happens if CRA rejects my taxpayer relief request — can I ask for a second review?

Yes. If CRA rejects a taxpayer relief request, you can generally ask for a second-level review of that decision, which is a further discretionary review conducted within CRA by different personnel than those who made the initial decision. This gives you a real second opportunity to have the same request reconsidered, rather than treating an initial rejection as final.

If the second-level review also results in a rejection, a taxpayer can, in some circumstances, ultimately seek judicial review of CRA's refusal in Federal Court, but this is a different and more limited kind of review than simply asking CRA to reconsider - a court reviewing CRA's decision is generally looking at whether CRA exercised its discretion properly and followed a fair process, not simply re-deciding the merits of your original request from scratch. This multi-step path gives you real options if an initial request doesn't succeed, but it's worth being realistic rather than overly optimistic about the odds of success at any particular level, since each stage involves its own specific standard and process. Understanding the difference between asking CRA to look again and asking a court to review how CRA exercised its discretion is important before deciding how to pursue a rejected request further.