- Once received, your objection goes to the CRA's Appeals Branch — a division separate from the auditor or team that made the original assessment.
- The appeals officer will typically: - Review the original audit or assessment file and the reasons behind it - Review your Notice of Objection and any supporting documents you provided -…
- Don't be surprised if the appeals officer reaches out with questions or requests for more documentation.
You've filed your Notice of Objection. Now what? The period after filing can feel like a black box — the CRA doesn't announce a fixed schedule, and it's easy to wonder whether anything is happening at all. Understanding what's going on behind the scenes, and what your options are at each point, makes the waiting more manageable.
Here's what actually happens after filing a CRA objection, from the moment it lands at the Appeals Division to the possible outcomes.
Stage 1: The Objection Is Assigned to an Appeals Officer
Once received, your objection goes to the CRA's Appeals Branch — a division separate from the auditor or team that made the original assessment. It's eventually assigned to an appeals officer, whose job is to review the file independently, not simply to defend the original assessment.
How long this assignment takes varies significantly based on the CRA's current workload and the complexity of the file — the CRA does not commit to a fixed turnaround, and estimates you see elsewhere should be treated with caution rather than relied on as a promise.
Stage 2: The Appeals Officer Reviews the File
The appeals officer will typically:
- Review the original audit or assessment file and the reasons behind it
- Review your Notice of Objection and any supporting documents you provided
- Potentially contact you or your representative for additional information, clarification, or documents
- Assess the legal and factual merits of the position independently
This is a genuine, fresh look — appeals officers are not bound to uphold whatever the original auditor decided, and objections do result in full or partial reversals of the original assessment.
Stage 3: You May Be Contacted for More Information
Don't be surprised if the appeals officer reaches out with questions or requests for more documentation. Responding promptly and completely helps keep your file moving and gives the officer what they need to reconsider the assessment. Delayed or incomplete responses can slow the process further and, in some cases, weaken your position if key facts remain unsupported.
Stage 4: The Appeals Officer Issues a Decision
Eventually, the CRA will send a decision — most often a Notice of Confirmation (upholding the assessment), a Notice of Reassessment (adjusting it, in whole or in part), or, less commonly, confirmation that the objection resulted in the assessment being vacated. The decision letter explains the reasoning and confirms your further appeal rights and deadlines if you disagree.
Possible Outcomes
| Outcome | What it means |
|---|---|
| Objection allowed in full | The CRA agrees with you and reassesses accordingly |
| Objection allowed in part | Some adjustments made, but not everything you sought |
| Objection confirmed | The CRA maintains its original position |
| CRA takes no action within the statutory window | You gain the right to appeal to the Tax Court without waiting for a decision |
If you disagree with the outcome — or if the CRA takes too long to respond — your next step is an appeal to the Tax Court of Canada, a separate judicial process with its own deadline running from the CRA's decision (or from CRA's inaction after a set period).
What to Do While You Wait
- [ ] Keep copies of everything you submit and every piece of correspondence you receive
- [ ] Respond promptly to any request from the appeals officer
- [ ] Continue paying what you reasonably can toward any amount in dispute — interest generally continues to accrue on unpaid amounts during the objection process
- [ ] Track your Tax Court appeal deadline so it doesn't pass unnoticed if the CRA doesn't respond within the statutory window
- [ ] Keep your contact information current with the CRA so decision letters and requests reach you
When to Get a Lawyer Involved
Many straightforward objections are resolved without a lawyer. But it's worth getting advice if:
- The amount in dispute is significant
- The appeals officer's questions suggest the file may be heading toward a gross negligence penalty or a criminal referral
- You've received a Notice of Confirmation and are considering a Tax Court appeal
- The issue involves a complex area like worker classification, corporate reorganization, or an estate
Frequently asked questions
Can I still negotiate with the appeals officer, or is it all-or-nothing?
Appeals officers do have some room to negotiate a resolution, particularly where the facts are genuinely disputable or partially in your favour, though what an officer can settle informally is more limited than many taxpayers expect. Understanding what's actually negotiable is worth discussing with someone familiar with the process.
What if the CRA takes a very long time to respond to my objection?
The Income Tax Act allows you to appeal to the Tax Court if the CRA hasn't responded to your objection within a set statutory period, even without a Notice of Confirmation. This gives you a path forward without waiting indefinitely, though whether it makes sense to use it depends on your specific file.
Does filing an objection stop collection action?
For most individual income tax objections, the CRA generally holds off on collection action on the disputed amount while the objection is pending, though this is not absolute and doesn't apply the same way to every type of tax debt or every taxpayer. Confirm your specific situation rather than assuming collections are automatically paused.
Will interest keep growing while my objection is being reviewed?
Generally yes — interest typically continues to accrue on any unpaid balance during the objection process. If your objection succeeds, amounts you've paid are refunded with interest, but if it fails and you haven't been paying, the balance (including interest) will have grown in the meantime.
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