- For most individuals the normal reassessment period ends three years after the earlier of the date of the original notice of assessment and the date of the original notification that no tax is payable.
- The CRA can reassess after that period in listed cases, including misrepresentation, fraud, a valid waiver or a taxpayer relief request.
- Where a misrepresentation is attributable to neglect, carelessness or wilful default, or where fraud was committed, there is no fixed time limit, but the reassessment is limited to the related matter.
You filed your return, received a notice of assessment, and moved on. Then a letter arrives about a year that feels long ago. It is natural to ask whether the CRA is allowed to look that far back.
The short answer is that there is a normal time limit, but it has exceptions. This article explains the normal period, the situations that extend it, and the cases where no fixed limit applies.
This article covers Canadian federal tax law, which applies in every province.
The normal reassessment period
A reassessment is the CRA changing an assessment it has already issued. For individuals, trusts other than mutual fund trusts, and Canadian-controlled private corporations, the normal reassessment period ends three years after the earlier of the date of the original notice of assessment and the date of the original notification that no tax is payable.
Once that period ends, tax, interest or penalties generally cannot be assessed unless a listed exception applies.
| Taxpayer | Normal reassessment period |
|---|---|
| Individuals, trusts other than mutual fund trusts, and CCPCs | Three years from the earlier of the original notice of assessment and the original notification that no tax is payable |
| Mutual fund trusts and corporations other than CCPCs | Four years |
When the CRA can reassess after the normal period
The Income Tax Act lists the situations in which the CRA can go back further. The main ones are below.
- Misrepresentation or fraud in filing the return or supplying information.
- A valid waiver, which lets the CRA reassess later but only for the matters the waiver specifies.
- Certain items listed in s. 152(6), such as some loss and investment tax credit carrybacks, which extend the normal period by three years.
- A taxpayer relief request, where the CRA may reassess to the extent of the request.
When there is no fixed time limit
If you made any misrepresentation attributable to neglect, carelessness or wilful default, or committed fraud, in filing the return or supplying information, the CRA may reassess after the normal period and there is no fixed time limit.
There are limits on this. A reassessment after the normal period under the misrepresentation, fraud or waiver exceptions is allowed only to the extent it can reasonably be regarded as relating to the matter that triggered the exception. The CRA also generally does not use the misrepresentation exception to reduce tax payable.
If you appeal an assessment made after the normal period, the burden of establishing misrepresentation lies on the CRA. It must show at least one misrepresentation that a normally wise and cautious taxpayer would not have made, even if made in good faith. Once the right to reassess is established, the onus shifts to you on the amount.
Waivers deserve extra care
A waiver filed on Form T2029 within the normal period lets the CRA reassess later for the specified matters. A waiver included in the return when it is originally filed is not valid.
A waiver limits the Minister's power to reassess to the matters specified in it or reasonably related to them. The CRA's own manual says a waiver should be as specific as possible, and a waiver naming only the company and year is not in the taxpayer's favour.
A waiver can be revoked using Form T652. The revocation takes effect six months after the notice is filed and cannot be rescinded once filed.
What to do if you receive a reassessment
A reassessment is not automatically correct or automatically final. An assessment is deemed valid and binding despite any error, defect or omission, but it can be varied or vacated on objection or appeal. The Minister is also not bound by the return or information you supplied.
- Find the date of the original notice of assessment, or of any original notification that no tax is payable, for the year in question. Count the normal period from the earlier of the two.
- Read the reassessment to see which exception, if any, the CRA is relying on.
- Check the objection deadline. An individual (other than a trust) must serve a notice of objection by the later of one year after the filing-due date and 90 days after the notice of assessment was sent.
- Keep your records for the year. Books and records must generally be kept for a minimum of six years.
- Remember that interest on unpaid tax continues to run while an amount is outstanding.
- Speak with a lawyer or accountant before signing any waiver or responding on a closed year.
Frequently asked questions
Is the CRA limited to three years for every taxpayer?
No. Three years is the normal period for individuals, trusts other than mutual fund trusts, and CCPCs. Mutual fund trusts and corporations other than CCPCs have four years.
Can the CRA reassess a return if I made an honest mistake?
Possibly. The misrepresentation exception covers neglect, carelessness or wilful default, not only fraud. On appeal, the CRA must show a misrepresentation that a normally wise and cautious taxpayer would not have made, even if made in good faith.
Can I cancel a waiver I signed?
Yes, a waiver can be revoked using Form T652. The revocation takes effect six months after the notice is filed and cannot be rescinded.
What if the CRA reassesses a year outside the normal period?
The reassessment must fit one of the listed exceptions. Under the misrepresentation, fraud or waiver exceptions it is limited to what relates to the triggering matter. A lawyer or accountant can review whether the exception truly applies.
Sources
- CRA Information Circular IC75-7R3, Reassessment of a Return of Income — canada.ca
- Income Tax Act, s. 152 — Justice Laws (federal)
- CRA Income Tax Audit Manual, chapter 11 — canada.ca
- CRA RC4188, What you should know about audits — canada.ca
- CRA, Prescribed interest rates, Q4 2026 — canada.ca
- Income Tax Act, s. 165(1) — Justice Laws (federal)
Links go to official government, court and regulator pages. The law changes — confirm you are reading the current version.
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