- On receiving a notice of objection, the Minister must reconsider the assessment and then vacate, confirm, vary or reassess it, and notify you in writing.
- Generally you do not have to pay disputed income tax until the review is complete, but interest keeps accruing.
- If you disagree with the result, you can appeal to the Tax Court of Canada within 90 days of the CRA's decision.
Once you have filed an objection, you wait. Then a letter or a call arrives saying your file has been assigned to an appeals officer, and you wonder what happens next.
This article explains in general terms how the review fits into the objection process, what outcomes are possible, what happens to collection and interest, and how to prepare. The details of how any one officer handles a file vary, so a lawyer or accountant can help with your specific case.
This article covers Canadian federal tax law, which applies in every province.
Where the appeals officer fits in
The Minister examines a return, assesses tax, interest and penalties, and sends a notice of assessment. If you object, the notice of objection is addressed to the Chief of Appeals. The law then requires the Minister to reconsider the assessment.
Once the CRA receives your objection it gives you a case number, which should go in all later correspondence. Filing through a secure portal such as My Account, My Business Account or Represent a Client gets the objection assigned to an appeals officer sooner than paper.
What the review is and the outcomes possible
On receiving the objection, the Minister must reconsider the assessment and then vacate, confirm, vary or reassess it, and notify you in writing.
| Outcome | What it generally means |
|---|---|
| Vacate | The assessment is cancelled. |
| Confirm | The CRA agrees with its original assessment and sends a Notice of Confirmation. |
| Vary or reassess | The assessment is changed, in whole or in part. |
Your notice of objection must set out the reasons for the objection and all relevant facts. If information is missing, the officer may need to ask you for it. If you withheld information during an audit and gave it only with your objection, the file may be sent back for a second review.
Contact, information requests and settling
How and how often an appeals officer contacts you, and how a compromise is reached, depends on the file and the officer. You may be asked for more facts or documents. An authorized representative, such as an accountant, can file an objection for you through Represent a Client.
Whatever the discussion, the formal result is one of the outcomes above, and you are notified in writing. Keep notes of any call, with the date and the name of the person you spoke with, and follow up important points in writing under your case number.
If an issue is complex or the amounts are significant, it is sensible to have a lawyer or accountant take part in these discussions before you agree to anything.
How long it takes and what happens to payment
Processing time varies with complexity. For income tax objections resolved in August 2026, the average was 145 days for low complexity (credits, deductions, Canada child benefit) and 403 days for medium complexity (business expenses, partnerships, T2 issues), while high complexity files took over 690 days. These are monthly averages that change, and the time counted excludes time you take to provide more information.
- Generally, you do not have to pay disputed income tax until the review is complete. Amounts you were required to withhold and remit must still be paid on time.
- After a notice of objection is served, the Minister cannot take collection action on the disputed amount until 90 days after the decision confirming or varying the assessment is sent. There are exceptions: a large corporation or a taxpayer in certain tax shelter cases can be required to pay one-half of the assessed amount, and amounts that must be withheld and remitted fall outside the restriction.
- Interest keeps accruing on disputed income tax. Paying all or part of the disputed amount stops further interest on the amount paid, and it is refunded if the CRA agrees with you.
- If you have paid the disputed amount and get no decision within 120 days of filing, you can request a refund of it. The refund is limited to half for large corporations and charitable donation shelter cases.
GST/HST works differently. The CRA says it can keep collecting amounts you owe while a GST/HST objection is pending.
What to do next
- Write down your case number and the officer's contact details.
- Reread your objection so you know exactly what you argued.
- Organize supporting documents in the order of the issues.
- Respond to information requests promptly and keep copies.
- Diarize the 90 days after any decision, since you can appeal to the Tax Court of Canada within 90 days of a Notice of Confirmation or reassessment.
If 90 days have passed since your notice of objection was served and there is no decision vacating, confirming or reassessing, you may appeal to the Tax Court of Canada without waiting for the CRA. A lawyer or accountant can help you decide whether to wait.
Frequently asked questions
Will the appeals officer be the same person who audited me?
The rules in this area do not say, and it depends on the file. What the law does require is that the Minister reconsider the assessment and notify you in writing of the result.
Do I have to pay while the appeals officer reviews my file?
For income tax, generally you do not have to pay disputed amounts until the review is complete, though amounts you had to withhold and remit are still due. Interest keeps accruing, and paying stops it on the amount paid. GST/HST collection may continue.
What if I disagree with the result?
If the CRA sends a Notice of Confirmation or a reassessment, you can appeal to the Tax Court of Canada within 90 days. The Tax Court has Informal and General procedures.
Can I appeal to the Tax Court if the CRA never answers?
For income tax, you can appeal once 90 days have passed since the notice of objection was served with no decision. For GST/HST the wait is 180 days after the objection was filed.
Sources
- Income Tax Act, s.165 (Justice Laws) — Justice Laws (federal)
- CRA – File an objection – Income tax — canada.ca
- Income Tax Act, s.152 (Justice Laws) — Justice Laws (federal)
- CRA Guide P148 — canada.ca
- Income Tax Act, s.225.1 (Justice Laws) — Justice Laws (federal)
- CRA – Processing times and complexity levels, income tax and GST/HST objections — canada.ca
- Income Tax Act, s.169 (Justice Laws) — Justice Laws (federal)
- CRA – File an appeal to the Court – Income tax or GST/HST — canada.ca
Links go to official government, court and regulator pages. The law changes — confirm you are reading the current version.
This is a tax question
A tax planning consult with us is from $563.87, tax included. Third-party fees are extra.