CRA Notice of Objection 2025 — Dispute CRA Assessments, Stop Collections, and Win Back Your Rights with Mackisen CPA

CRA’s reassessment volume has reached record highs as automated systems issue adjustments and penalties faster than ever before. Many taxpayers are receiving notices they don’t fully understand — often containing errors, duplicated income, or denied deductions. What most Canadians don’t realize is that they have only 90 days to respond through a formal Notice of Objection before losing their legal right to appeal. At Mackisen CPA Auditors Montreal, we prepare and file precise, evidence-backed Notices of Objection that stop CRA collection, reopen your case, and correct the record. Our CPA auditors and tax lawyers handle every step, from audit review to legal argumentation, ensuring fairness and financial protection. We don’t let CRA’s systems go unchallenged — we make them accountable.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 165(1): Grants every taxpayer the right to file a Notice of Objection within 90 days of a reassessment. Section 166.1(1): Allows an extension of time to file up to one year beyond the 90-day deadline if justified. Section 220(3.1): Enables CRA to cancel penalties and interest after an objection is resolved through the Taxpayer Relief Program. Section 152(4): Limits CRA’s reassessment period to three years unless fraud or misrepresentation is proven. Section 225.1(1): Suspends CRA collection activity once a valid objection is filed.
Tax Administration Act (Quebec) Revenu Québec applies a similar objection process at the provincial level. Mackisen coordinates both CRA and Revenu Québec objections to ensure consistent and complete protection across all jurisdictions.

Key Court Decisions

Bédard v. The Queen (2022): Taxpayers have the absolute right to dispute CRA reassessments within legal timelines. Thibault v. The Queen (2022): CRA must fairly review all new evidence submitted during objection. Guindon v. Canada (2015): CRA penalties cannot stand when honest mistakes are proven. Jordan v. The Queen (2009): Taxpayer objections must be handled impartially and within reasonable time. These rulings confirm that the Notice of Objection is one of the strongest legal tools for taxpayer justice.

Why Filing an Objection Matters

CRA’s reassessment system is not infallible. Automated processing can lead to double-counted income, missed credits, or inaccurate assumptions about your business. Filing a Notice of Objection not only pauses collections but gives you the opportunity to prove your case with evidence. Common 2025 triggers include denied deductions, capital gains reclassification, GST/HST audit errors, or unreported income assumptions. CRA assumes liability — Mackisen proves accuracy.

Mackisen’s Notice of Objection Strategy

1. Reassessment Review: Analyze the CRA audit report and identify factual or procedural errors. 2. Evidence Preparation: Gather contracts, receipts, and statements to support your position. 3. Filing and Suspension: Submit a Notice of Objection within the 90-day deadline to stop all CRA collection. 4. Appeals Representation: Engage CRA Appeals Officers directly to negotiate adjustments or reversals. 5. Penalty & Interest Relief: File a Taxpayer Relief Request under Section 220(3.1) for cancelled penalties once resolved. Mackisen’s method ensures your case is heard, your evidence respected, and your rights restored.

Real Client Experience

A Montreal real estate investor received a $362,000 reassessment for “unreported gains.” Mackisen filed a Notice of Objection and CRA reversed the entire assessment within eight weeks. A Quebec business was charged $74,000 in payroll penalties. Mackisen filed an objection proving administrative error, and CRA cancelled every penalty.

Common Questions

Can I file a Notice of Objection myself? Yes, but Mackisen’s professional filing ensures accuracy and stronger results. Can CRA collect money while I appeal? No, collections stop automatically after filing a valid objection. What if I miss the 90-day deadline? Mackisen can apply for a one-year extension under Section 166.1. Can CRA remove penalties and interest after appeal? Absolutely — we request full relief under the Taxpayer Relief Program.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leaders in filing and defending CRA Notices of Objection. Our integrated team of accountants and tax lawyers ensures your appeal is accurate, strategic, and legally airtight. We act quickly, argue powerfully, and defend relentlessly — because your rights should never expire. When CRA reassesses, Mackisen objects with authority. Call Mackisen CPA Auditors Montreal today for your 2025 Notice of Objection Consultation. The first meeting is free, and your protection starts immediately.