Which CRA Decisions Can You Object To in Canada?

A letter from the CRA does not always carry the right to object. Some documents are formal decisions with set rights and deadlines, and others are just information or a proposal.

This article helps you sort the two. Knowing which kind of notice you hold is the first step before you spend time on a notice of objection.

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

Decisions that carry objection rights

After examining a return, the Minister assesses tax, interest and penalties and sends a notice of assessment to the person who filed it. The CRA says you can object to a notice of assessment, reassessment, determination or redetermination.

The objection and appeal rights for assessments also apply to determinations such as the Canada child benefit, the GST/HST credit, the disability tax credit and loss determinations. The Minister must determine an unreported loss (non-capital, net capital, restricted farm, farm or limited partnership loss) at your request, and the assessment provisions, including objection rights, apply to that determination.

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 is why it matters to know early whether a notice is one you can challenge.

Things you cannot object to

The CRA lists examples that cannot be objected to:

• RRSP or TFSA room statements.
• Carryforward balances and Home Buyers' Plan balances.
• Refund interest, tax deducted at source and OAS recovery tax.
• Set-offs, statements of account, pension adjustments and nil assessments.
• An auditor's proposal letter.

If you are in a loss position, you cannot object until a notice of loss determination is issued, and you can request one from the tax services office or tax centre. You also cannot object to an issue on which you waived your right of objection in writing, and that waiver bars a Tax Court appeal on it as well.

Being unable to object does not always mean there is no other route. An individual (other than a trust) or graduated rate estate may ask for a reassessment to claim a refund or reduction up to 10 calendar years after the end of the taxation year, and that is a request for adjustment, not an objection. The Minister may also waive or cancel all or part of a penalty or interest for a taxation year, up to ten calendar years after the end of that year.

A quick comparison

Timing and special cases

Objections filed late or before the notice was issued may be invalid. For most individuals the deadline is the later of one year after the filing-due date and 90 days after the notice of assessment was sent. Loss determinations and RRSP or TFSA over-contribution assessments carry only a 90-day limit.

Penalties and interest are part of the assessment, so a notice of objection can dispute them. Asking the CRA to cancel or waive them on fairness grounds is a separate request. A reassessment issued under the Taxpayer Relief provisions cannot itself be objected to.

GST/HST has its own rules. An objection must be filed within 90 days after the day notice of assessment is sent.

If the deadline has passed, you may apply to the Minister for an extension. The application must give the reasons for the delay and be addressed to the Chief of Appeals, with a copy of the notice of objection. An extension can be granted only if the application is made within one year after the objection deadline expired, and you must also show that you were unable to act or had a bona fide intention to object, that granting it is just and equitable, and that you applied as soon as circumstances permitted.

How an objection works once you have one

A notice of objection is a written notice that sets out the reasons for the objection and all relevant facts. It is served by addressing it to the Chief of Appeals at a CRA District Office or Taxation Centre and delivering or mailing it there. You can also file online through My Account for Individuals or My Business Account by selecting "Register my formal dispute", or through an authorized representative using Represent a Client.

CRA's page says Form T400A was cancelled as of 2026-10-26 and replaced with Form RC592, Notice of Objection, which is a fillable PDF opened in Acrobat Reader 10 or later rather than in a web browser.

On receiving a notice of objection, the Minister must reconsider the assessment and vacate, confirm, vary or reassess it, then notify you in writing. If the CRA disagrees with you, it sends a Notice of Confirmation or a reassessment, and you can then appeal to the Tax Court within 90 days.

Generally, you do not have to pay disputed income tax until the objection review is complete, but interest keeps accruing on it. Amounts you were required to withhold and remit must still be paid on time. GST/HST works differently, since CRA says it can keep collecting while a GST/HST objection is pending.

What to do next

• Read the heading of your letter: is it a notice of assessment, reassessment or determination, or a statement or proposal?
• Note the date on the notice, since your deadline runs from it.
• If it is only a proposal letter, consider responding to the auditor and keep your own records.
• If you are unsure what the document is, ask a lawyer or accountant before the deadline passes.
• If it is objectable, prepare your reasons, facts and supporting documents.

Frequently asked questions