Resolving disputes

If you disagree with the Notice of Assessment you receive, contact us.

If you are not satisfied with our answer after talking to us, you have the right to make a formal objection.

You can make a formal objection if you disagree with the amount of tax, interest, or penalties we have assessed or reassessed.

Make a formal objection

Make a formal objection in one of the following ways:

• Use the "Register a formal dispute" service at Represent a client, if you are a authorized representative or employee; or in My Business Account if you are a business owner.
• Complete and file Form T400A, Objection - Income Tax Act.
• Send a letter to the Chief of Appeals at your tax services office or tax centre.

You must explain the reasons for the objection and outline all the relevant facts.

You have 90 days from the date of the Notice of Assessment, or reassessment, to file the objection.

Appealing loss amounts

Appealing a loss has a different formal objection process because there is no tax, interest, or penalty involved. See Appealing loss amounts for more information.

How objections are processed

Once we receive the objection, we review the assessment or reassessment in dispute. We then contact the corporation or its authorized representative to discuss the differences and try to resolve the dispute.

If the differences cannot be resolved, the corporation can then appeal the assessment or reassessment to the Tax Court of Canada.

Payment of disputed amounts

You do not have to pay the disputed amount of tax, interest, or penalty while you are waiting for the outcome of the CRA's or the Tax Court of Canada's review. However, any amounts you owe, or any amounts that we owe you, at the end of the objection or appeal process will be charged interest calculated from the balance due date.

For more information, see Booklet P148, Resolving Your Dispute: Objections and Appeal Rights under the Income Tax Act.

Large corporations

A large corporation is a corporation that has over $10 million in total taxable capital employed in Canada by it and its related corporations at the end of the tax year.

The Income Tax Act describes specific requirements for large corporations.

Notice of objection requirements for large corporations

For a large corporation, the notice of objection has to:

• reasonably describe each issue
• specify the relief you are seeking, expressed as the amount of a change in the income, taxable income, loss, taxes payable, refundable amounts, and overpayments or a balance of unclaimed outlays, expenses, or other amounts of the corporation
• provide facts and reasons the corporation relied on for each issue

Payment of disputed amounts for large corporations

A large corporation, or a corporation related to a large corporation, that objects to an assessment has to pay 50% of the disputed amount and must also pay the full amount of taxes not in dispute.

Forms and publications

• Guide T4012, T2 Corporation  -  Income Tax Guide
• Booklet P148, Resolving Your Dispute: Objections and Appeal Rights under the Income Tax Act
• Form T400A, Objection - Income Tax Act

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