Filing a CRA Objection for a Deceased Taxpayer or Estate in Canada

If you are an executor and CRA has reassessed a deceased person's return, you may be asked to pay more tax or you may disagree with how something was treated. Dealing with a reassessment while also settling an estate is stressful, and the deadlines do not pause for grief.

This article walks through the general rules for objecting, what a notice of objection should contain and how to file it. The details of who may sign for an estate depend on the facts, so a lawyer or accountant should confirm them before you file.

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

Start with the notice and its date

The Minister examines a return, assesses tax, interest and penalties, and sends a notice of assessment. A notice of reassessment issued within or after the normal reassessment period starts new objection rights over the reassessed items. An assessment is deemed valid and binding despite any error, defect or omission, subject to objection, appeal and reassessment.

That last point matters. If you do nothing, the assessment stands. Find the date printed on the notice, because the 90-day period runs from the day the notice was sent, not the day it was received.

How long the estate has

An individual (other than a trust) or a graduated rate estate has until the later of one year after the taxpayer's filing-due date for the year and 90 days after the notice of assessment was sent. Any other taxpayer, such as a corporation or a trust that is not a graduated rate estate, has 90 days after the notice of assessment was sent.

Whether the estate you are administering counts as a graduated rate estate, and which period applies to the year in question, depends on the facts. If you are unsure, the safe approach is to work from the 90-day date and confirm the longer period with a lawyer or accountant.

Some notices carry only 90 days even for individuals, such as loss determinations and RRSP or TFSA over-contribution assessments.

What the notice of objection should contain

The objection must be in writing and set out the reasons and all relevant facts. CRA's guidance says it should contain these items:

• The name, complete mailing address and daytime phone number of the person filing.
• The notice date, the tax year and the SIN, business number or other account number.
• The relevant facts and reasons, with copies of supporting documents.
• The representative's name and address, if there is one.
• A signature and date. For a corporation or trust, an authorized officer signs.

How the estate's authority should be shown depends on your situation, so it is worth confirming with a lawyer before you file. If someone files for you, the notice should include the representative's name and address.

Penalties and interest are part of the assessment, so a notice of objection can dispute them. Cancelling or waiving them as a matter of fairness is a separate request, not an objection.

How to file, and what to expect

Options include filing online through My Account or My Business Account by selecting "Register my formal dispute", or through an authorized representative using Represent a Client. You can also mail or fax a signed letter or form to the Chief of Appeals, or deliver it in person. CRA says portal submissions are assigned to an appeals officer sooner than paper. CRA's paper form T400A was cancelled as of 2026-10-26 and replaced by Form RC592, Notice of Objection.

Once the objection is received, CRA gives a case number to use in all later correspondence. The Minister must reconsider and then vacate, confirm, vary or reassess, and notify you in writing.

Generally, disputed income tax does not have to be paid until the objection review is complete, but interest keeps accruing. Paying all or part stops further interest on the amount paid, and it is refunded if CRA agrees with you. If you are an executor, this can affect when you distribute estate property, so talk to a lawyer first.

If CRA confirms the assessment, you can appeal to the Tax Court of Canada within 90 days.

If a deadline has passed, and what to do next

You may apply to the Minister for an extension if no objection was made in time. The application must be made within one year after the objection deadline expired and meet the conditions in the Act. After that year, no extension can be granted.

• Note the date on the notice of reassessment and calculate the deadline.
• Gather the return, the notice and supporting records.
• Confirm with a lawyer or accountant who may sign for the estate.
• Write out the facts and your reasons.
• File through a secure portal or by mail, and keep the case number.

Frequently asked questions