Taxpayer Relief Request vs Notice of Objection in Canada

You have a CRA notice showing tax, a penalty or interest that you think is wrong, unfair or both. Two different routes exist, and they are easy to confuse: a notice of objection and a taxpayer relief request. They answer different questions, follow different timelines and lead to different next steps.

This article explains what each route does, when each one fits, and how the deadlines differ. It is general information. If a large amount or a looming deadline is involved, a lawyer or accountant can look at your actual notice.

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

The basic difference

A notice of objection says the assessment is wrong. You set out your reasons and all relevant facts in writing, and the CRA must reconsider the assessment and then vacate, confirm, vary or reassess it.

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. Under the Income Tax Act the Minister may waive or cancel all or part of a penalty or interest.

When an objection fits

An objection fits when you believe the CRA got the facts or the law wrong. That includes the tax itself and any penalties or interest calculated from it. Objections can be filed against a notice of assessment, reassessment, determination or redetermination.

Some things cannot be objected to, such as statements of account, an auditor's proposal letter, RRSP or TFSA room statements, and nil assessments. You also cannot object to an issue on which you waived the right of objection in writing.

• The deadline for most individuals is the later of one year after the filing-due date for the year and 90 days after the notice of assessment was sent.
• Corporations and most other taxpayers have 90 days after the notice was sent.
• 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 90 days, even for individuals.

When a relief request fits

A relief request fits when the assessment may be arithmetically correct but you want the penalty or interest cancelled or waived on fairness grounds. The Minister may do this for a taxation year, or on an application made, up to ten calendar years after the end of that year.

That ten-year reach is far longer than the objection window, so relief can still be possible when an objection is out of time. The Minister may make any assessment needed to give effect to relief despite the usual reassessment limits. What counts as a good reason and what the CRA tends to accept depends on the facts, so a lawyer or accountant can help you frame it.

Effects on paying and collection

Generally you do not have to pay disputed income tax until the objection review is complete, though amounts you were required to withhold and remit must still be paid on time. After a notice of objection is served, the Minister generally 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, but this does not cover amounts that must be withheld and remitted, Part VIII or s.281 amounts, or cases the CRA treats as in jeopardy. Large corporations and certain tax shelter cases can also be required to pay one-half of the assessed amount within 90 days of the notice of assessment.

These collection limits do not apply to assessments made under the relief provision, s.220(3.1). Interest keeps accruing on disputed income tax during an objection, and paying all or part of the amount stops further interest on what you paid. If the CRA agrees with you, that payment is refunded.

GST/HST works differently: the CRA says it can keep collecting while an objection is pending.

Choosing and next steps

Many people have both issues, such as a disputed assessment plus penalties they would like waived. The two routes are separate, so you can think about each on its own timeline. Missing an objection deadline does not necessarily close the relief route, given the ten-year limit.

• Find the notice date on your notice of assessment or reassessment and calculate your deadline from it.
• Decide whether you dispute the assessment itself or only want penalties and interest cancelled.
• If objecting, file online through My Account or My Business Account, through a representative using Represent a Client, or by mail or fax to the Chief of Appeals.
• Include your name, address, phone number, notice date, tax year, account number, facts, reasons and supporting documents, and sign and date it.
• Note that Form T400A was cancelled as of 2026-10-26 and replaced by Form RC592, Notice of Objection.
• If the objection deadline has passed, an extension application must be made within one year after it expired.
• Keep the case number the CRA gives you for later correspondence.

Frequently asked questions