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№ ix Tax

What to Expect When a CRA Appeals Officer Reviews Your Objection in Canada

See how a CRA appeals officer review of your objection generally works in Canada: timing, collection, the possible outcomes and what to do next.

Tax5 min readTSLBy the Treadstone Law Team · CanadaUpdated November 6, 2026
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Key takeaways
  • 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.

OutcomeWhat it generally means
VacateThe assessment is cancelled.
ConfirmThe CRA agrees with its original assessment and sends a Notice of Confirmation.
Vary or reassessThe 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.

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

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

Links go to official government, court and regulator pages. The law changes — confirm you are reading the current version.

This article is general information, not legal advice. Reading it does not create a lawyer-client relationship. Canadian laws, tax rates, and government programs change, and how the law applies depends on your specific facts. For advice about your situation, speak with a tax lawyer or accountant. Reach us at 1-844-900-1070 or send our Team a message.

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