CRA Collection Restrictions While Your Objection Is Pending in Canada

A notice of assessment with a balance owing can bring fear of collection calls, bank freezes or garnishment. If you are disputing the assessment, an important question is what the CRA is allowed to do while your objection is open.

For income tax, the law gives real protection, but it has limits and exceptions. This article explains the rule, when it ends, and where it does not apply.

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

The general rule for income tax

Generally, you do not have to pay disputed income tax until the objection review is complete. Under section 225.1(2) of the Income Tax Act, once a notice of objection is served the Minister cannot take collection action on the disputed amount until 90 days after the day notice of the decision confirming or varying the assessment is sent. The CRA says it normally postpones collection until 90 days after it sends its decision.

The protection covers the disputed amount. It does not erase any part of the balance you are not disputing, so think about whether you are objecting to the whole assessment or only part of it.

The protection starts once you serve a written notice of objection that sets out your reasons and all relevant facts. For an individual other than a trust, the deadline is the later of one year after the filing-due date for the year and 90 days after the notice of assessment was sent, while a corporation has 90 days. The 90 days run from the day the notice was sent, not the day you received it. Loss determinations and RRSP or TFSA over-contribution assessments have only a 90-day limit, even for individuals.

On receiving your objection, the Minister must reconsider the assessment and vacate, confirm, vary or reassess it, then notify you in writing. For income tax objections resolved in August 2026, the CRA average was 145 days for low complexity matters and 403 days for medium complexity matters, and these figures change monthly.

If you appeal to the Tax Court

Once you appeal to the Tax Court of Canada, collection of the disputed amount is barred until the Court's decision is mailed to you or you discontinue the appeal, whichever comes first. The same applies to a question referred to the Court. You can appeal after the Minister confirms or reassesses, within 90 days of the day that notice was sent.

Where the protection does not apply

• Assessments under sections 152(4.2), 169(3) or 220(3.1), amounts under Part VIII or section 281, amounts that must be withheld and remitted, certain section 116 tax, and related penalties and interest.
• Cases where the CRA considers an amount to be in jeopardy.
• Large corporations (taxable capital employed in Canada, with related corporations, over $10 million) and taxpayers in certain tax shelter cases, who can be required to pay one-half of the assessed amount within 90 days of the notice of assessment.
• Amounts you were required to withhold and remit, which must be paid on time and are not postponed.

Interest, paying early and refunds

Not being collected from does not mean interest stops. Interest keeps accruing on disputed income tax during an objection. Paying all or part of the disputed amount stops further interest on the amount paid, and if the CRA agrees with you the payment is refunded.

If you have paid the disputed amount and receive no decision within 120 days of filing, you can request a refund of it, but the refund is limited to half for large corporations and charitable donation shelter cases. Separate requests, such as a refund of disputed amounts, go to the Chief of Appeals with your case number.

GST/HST is different

The CRA says it can keep collecting amounts you owe while a GST/HST objection is pending, unlike income tax. Interest still applies, and you can pay all or part of the disputed amount to limit it.

The timelines also differ. A GST/HST objection must be filed within 90 days after the day the notice of assessment is sent. A GST/HST Tax Court appeal is allowed once the Minister has confirmed or reassessed, or 180 days after the objection was filed with no decision. Income tax uses a 90-day wait instead, so do not mix the two.

What to do next

• Confirm your objection was filed in time and keep your case number.
• Check whether your debt falls under one of the exceptions, such as unremitted withholdings.
• If you receive a collection letter after objecting, reply in writing, quote your case number, and refer to the objection.
• Note the 90-day Tax Court deadline from any confirmation or reassessment.
• Get advice from a lawyer or accountant if you face a jeopardy situation, are a large corporation, or are dealing with GST/HST.

Frequently asked questions