Ontario Corporations Tax

Serving an objection with the Minister

If you believe we have misinterpreted the facts or applied the law incorrectly, you have the right to object to most:

• assessments and reassessments; and
• determinations and re-determinations.

Serving an objection is the first step in the formal process of resolving a dispute. You can serve an objection by using Form ON100, Notice of Objection - Ontario Corporations Tax Act, and sending it by registered mail to the Chief of Appeals at your tax services office or tax centre. In all cases, you have to clearly describe each issue raised and fully set out the facts and reasons relied on for each issue.

The time limit for serving an objection is 180 days from the date of the Notice of Assessment or Determination.

Objections concerning premium taxes must still be served with the Ontario Ministry of Revenue.

Time Extension – Notice of Objection

You can apply for a time extension to serve your objection by writing to the Chief of Appeals at your tax services office or tax centre. You have to explain why you cannot or did not serve your objection on time.

Apply as soon as possible, but the application must be made:

• before the expiration of the 180-day period to serve an objection; or
• within one year from the date of the Notice of Assessment or Determination.

Filing an appeal with the court

If you disagree with our decision resulting from an objection, you can appeal your assessment or determination to the Ontario Superior Court of Justice.

You can file an appeal by using Form ON200, Notice of Appeal - Ontario Corporations Tax Act. You must go, in person, to your local court office of the Ontario Superior Court of Justice to file the Notice of Appeal and to pay the applicable court filing fee. You must also serve on the Minister the said appeal by sending one copy of the Notice of Appeal as filed, including the action number and the court location. Send it by registered mail to the Canada Revenue Agency, c/o Assistant Commissioner, Appeals Branch, 250 Albert Street, 14th Floor, Ottawa, Ontario, K1A 0L5.

You must file the Notice of Appeal with the Ontario Superior Court of Justice, and serve the appeal on the Minister, within 90 days from the date of the notification that the Minister has confirmed the assessment or has reassessed.

You must still serve appeals concerning premium taxes with the Ontario Ministry of Revenue.

Time Extension – Notice of Appeal

You can apply for a time extension to file an appeal with the Ontario Superior Court of Justice and to serve an appeal on the Minister by writing to the Assistant Commissioner, Canada Revenue Agency, Appeals Branch, 250 Albert Street, 14th Floor, Ottawa, Ontario, K1A 0L5.

Apply as soon as possible, but the application must be made before the expiration of the 90-day period to file/serve an appeal. You have to explain why you cannot file/serve your appeal on time.