OUR SERVICES
OBJECTIONS
What You Need to Know About Filing a Notice of Objection
When the Canada Revenue Agency (CRA) issues a reassessment, it can feel overwhelming—especially if the adjustments are inaccurate or unfair. Many small business owners face challenges like unreported income claims, HST/GST issues, or penalties that seem excessive. We specialize in helping businesses like yours challenge CRA decisions through the formal Notice of Objection process.
Common Issues We Handle
- Real Estate “Flipping” disputes.
- HST/GST builder-related concerns.
- Net-Worth Assessments involving unreported income.
- Disputes over CEWS and CERS subsidies.
- Penalties for alleged gross negligence.
How the Objection Process Works
Filing Your Notice of Objection (NOO)
You have 90 days from the date on your Notice of Assessment or Reassessment to formally file an objection with the CRA’s Appeals Division.
Appeals Officer Review
Your case will be assigned to an Appeals Officer, who will thoroughly review your objection and compare it with the CRA auditor’s position.
Decision
Making
The Appeals Officer may decide to:
- Fully agree with your objection and remove the reassessment.
- Partially accept your arguments and issue a revised reassessment.
- Reject the objection, which can be escalated to the Tax Court of Canada within 90 days.
Why Choose Bell Tax Advisory?
James, with over 33 years of experience in this field, including his 22+ years working at the CRA, is able to offer a unique perspective to resolve disputes efficiently and effectively. James and Bell Tax Advisory are committed to providing tailored solutions, strategic insights, and the dedicated support you and your clients need to achieve the best results.
Why Partner with Bell Tax Advisory?
Proven CRA Expertise
With over 22 years of CRA experience, we understand the inner workings of the system and how to position your case effectively.
Collaborative Legal Support
For complex cases, we partner with trusted tax law firms to ensure every angle of your objection is addressed.
Strategic Advocacy
Our team develops compelling arguments backed by evidence to secure the best possible outcome for your business.
When to
Act
If you disagree with a CRA decision, don’t delay. Filing a Notice of Objection quickly is crucial to preserving your rights and opportunities.
Testimonials
Frequently asked questions
What is a Notice of Objection?
A Notice of Objection is a formal response used to dispute a CRA assessment or reassessment. It initiates the appeal process and gives you an opportunity to explain why you disagree with the CRA’s decision. The notice must be filed within 90 days of the assessment date, though late filings are possible with a valid reason.
How do I file a Notice of Objection?
You can file a Notice of Objection using CRA’s online portal or by submitting a T400A form by mail. The objection must clearly identify the disputed assessment, state the issues, and explain your position. Supporting documentation strengthens your case. If you miss the 90-day deadline, you can request an extension (within one year).
What happens after I file an objection?
Once the CRA receives your objection, your file is assigned to an Appeals Officer. This can take several months. The officer will review your arguments, request supporting documents, and may propose a resolution. If your objection is successful, the assessment may be reversed or adjusted. If not, you may escalate the matter to the Tax Court of Canada.
Does filing an objection stop collections?
For income tax objections, filing a Notice of Objection typically pauses CRA collections while your case is under review. However, for HST or GST objections, the CRA can continue to pursue payment even while the objection is pending. In those cases, we engage CRA collectors directly to request holds on enforcement and negotiate manageable payment terms, ensuring your business isn’t disrupted while the dispute is resolved.
How long does it take to resolve an objection?
Timelines vary based on complexity and CRA backlogs, but most objections take 12 to 24 months to resolve. Simple matters may be handled faster, while more involved cases can take years, especially if they escalate to the Tax Court.
