Notice of Objection
A Notice of Objection is the formal filing that disputes a CRA assessment or reassessment and sends the file to the Appeals division for an independent second look.
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Key facts
| Category | Returns & filing |
|---|---|
| Also known as | objection, T400A, disputing a reassessment |
| Filed with | The CRA Appeals Branch; Revenu Québec has its own process |
| Individual deadline | The later of one year after the filing due date and 90 days after the notice |
| Corporate deadline | 90 days after the notice |
| Collection | Generally paused on disputed income tax for individuals; not for source deductions or GST/HST |
| Authority | Canada Revenue Agency; Revenu Québec |
What it means in practice
An objection is the required first step in the dispute process: you generally cannot go to the Tax Court of Canada without having filed one. It sets out what is being disputed and why, with the supporting facts and documents. Deadlines are strict. For individuals and testamentary trusts the limit is the later of one year after the filing due date and 90 days from the date on the notice of assessment or reassessment. Other taxpayers, including corporations, have 90 days from the date of the notice. Missing the window means applying for an extension, which is discretionary and not guaranteed. Filing an objection generally suspends CRA collection of the disputed income tax until the objection is decided. That protection is not universal: large corporations remain collectible for half the disputed amount, and it does not extend to GST/HST assessments or to source deductions, where collection continues regardless. Interest continues to accrue on any balance that ultimately stands, so a disputed amount that is eventually upheld costs more the longer the dispute runs. Québec has a parallel process for Revenu Québec assessments, with its own form and its own deadline.
The deadline is the whole game
An objection filed late is not considered on its merits. An extension can be applied for within a further year where there is a valid reason, but beyond that the assessment stands however wrong it is — which makes the date on the notice the first thing to record. An objection should set out the facts, the issue and the reasons, with the supporting documents attached. An appeals officer reviews the file independently of the auditor or processor who made the assessment, so material that was never provided during a review is worth including here. If the objection is denied, the next step is an appeal to the Tax Court of Canada, with its own deadline running from the confirmation.
FAQ
Do I have to pay while I object?
Can I just ask for a correction instead?
Need this applied to your situation?
A definition only gets you so far. Talk to a Montréal CPA about what this means for your return — in English or French.