Can a Lawyer Help You With a CRA Notice of Objection in Canada?

Many people file an objection on their own, and that is allowed. But if the amount is large, the issues are technical or the deadline is close, you may wonder whether a lawyer can help.

This article explains where a lawyer can be useful at each stage of the process. It does not promise any outcome, and the right level of help depends on your situation.

This article covers Canadian federal tax law, which applies in every province.

Understanding the assessment and deadline

A lawyer can start by reading the notice and working out what is being disputed and whether it can be objected to at all. You cannot object to a statement of account or an auditor's proposal letter. The CRA also lists items that cannot be objected to, such as carryforward balances and nil assessments.

They can also check the deadline. An individual (other than a trust) has the later of one year after the filing deadline and 90 days from the notice date, while corporations have 90 days. Some assessments have only a 90-day limit. Getting the deadline wrong can be costly, because an extension is limited to applications within one year after the deadline expired.

Drafting the grounds of objection

The notice must set out the reasons and all relevant facts. It should include your contact details, the notice date and tax year, the facts and reasons with copies of supporting documents, and be signed and dated.

Some taxpayers face stricter content rules. A large corporation's notice must describe each issue, state the relief sought for each issue and give facts and reasons. A lawyer can help present the issues clearly and in the form the Act requires.

If you withheld information during an audit and give it only with the objection, the file may be sent back for a second review. A lawyer can help you decide what to include and when.

Filing and dealing with Appeals

An authorized representative, such as an accountant, can file through Represent a Client by selecting "Register my formal dispute". The notice should include the representative's name and address if there is one.

Once an objection is received, the Minister must reconsider the assessment and vacate, confirm, vary or reassess it, then notify you in writing.

They can also advise on payment. Generally, you do not have to pay disputed income tax until the review is complete. Interest keeps accruing, and paying all or part of the disputed amount stops further interest on what you paid. Collection rules differ for GST/HST, where the CRA says it can keep collecting while the objection is pending.

Tax Court and what to do next

If the CRA disagrees with your objection, it sends a Notice of Confirmation or a reassessment, and you can appeal to the Tax Court within 90 days. The Tax Court has Informal and General procedures. A lawyer can advise which suits your case and prepare the appeal. You may also appeal if 90 days have passed since you served the objection with no decision.

Processing time varies. For income tax objections resolved in August 2026, the average was 145 days for low complexity and 403 days for medium complexity.

• Keep the notice of assessment and note the date it was sent.
• List the issues you disagree with and the facts behind each.
• Gather supporting documents and anything you gave the CRA earlier.
• Ask a lawyer early if the amount is large, the issues are technical or the deadline is near.
• Keep your case number once assigned.

Frequently asked questions