CRA Notice of Objection Denied 2025 — Reopen Your Case, Appeal to Tax Court, and Reverse CRA’s Decision

When the CRA denies your Notice of Objection, it feels like the end—but it’s not. In 2025, CRA’s appeals division is more automated, more selective, and less forgiving than ever. Many denials result not from merit, but from incomplete documentation or missing legal arguments. But here’s the truth: you still have powerful legal options. You can appeal directly to the Tax Court of Canada, reopen your file under the Taxpayer Relief Program, and challenge CRA’s denial through a structured legal defense.

At Mackisen CPA Auditors Montreal, we don’t let a denial define your outcome. Our CPA auditors and tax lawyers review the entire case, identify CRA’s procedural flaws, and prepare a Tax Court appeal that demands fairness. We’ve reversed hundreds of denials by combining precise accounting evidence with sharp legal strategy—because when the CRA says “no,” Mackisen finds the way to “yes.”

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 165(3): Gives CRA the authority to confirm, vary, or deny a Notice of Objection.

• Section 169(1): Grants taxpayers 90 days to appeal a denied objection to the Tax Court of Canada.

• Section 161(1): Applies daily compounded interest on reassessed balances until overturned.

• Section 220(3.1): Allows CRA to reduce penalties and interest under the Taxpayer Relief Program even after denial.

Tax Administration Act (Quebec)
Revenu Québec’s Appeals Division operates similarly, giving taxpayers 90 days to appeal a denied objection at the provincial level.

Mackisen coordinates both federal and provincial appeals simultaneously—ensuring your case is airtight and consistent across agencies.

Key Court Decisions

Venne v. The Queen (1984): Missing appeal deadlines after denial makes reassessments final and enforceable.
Guindon v. Canada (2015): Penalties are valid unless proven unreasonable or procedurally defective.
Thibault v. The Queen (2022): Tax Court rulings can overturn CRA denials when evidence and professional arguments are properly presented.
Jordan v. The Queen (2009): CRA must justify denial decisions with adequate reasoning; arbitrary rejections can be appealed successfully.

These cases show that the Tax Court exists to protect taxpayers from administrative overreach—if you act in time.

Why CRA Denies Objections

CRA denials often occur because the appeals officer:

• Deemed your evidence insufficient or inconsistent.

• Relied solely on the original auditor’s assumptions.

• Applied incorrect sections of the Income Tax Act.

• Ignored or overlooked supporting documents.

• Failed to consider hardship or relief applications.

The result? Taxpayers face inflated balances, penalties, and interest—all based on flawed reviews that can be overturned.

Mackisen’s Post-Denial Legal Defense and Appeal Strategy

1. File Review: Analyze CRA’s denial letter, appeal rationale, and procedural history for legal or factual errors.

2. Evidence Reconstruction: Rebuild and expand documentation to strengthen your case for Tax Court.

3. Tax Court Appeal Filing: Submit a formal appeal within 90 days of CRA’s denial to pause enforcement.

4. Negotiation and Settlement: Engage CRA counsel or Department of Justice lawyers to negotiate resolution before trial.

5. Taxpayer Relief Application: File parallel relief to reduce or eliminate penalties and interest during the appeal.

Our approach ensures your case is not just reopened—but rebuilt to win.

Real Client Experience

A Montreal entrepreneur’s objection was denied after CRA disallowed $112,000 in corporate expenses. Mackisen appealed to the Tax Court, presented full documentation, and achieved a complete reversal of CRA’s decision.
A Quebec contractor was denied an objection for GST/QST credits. Mackisen filed a new appeal and a relief application—CRA cancelled 80% of the balance and waived all penalties.

Common Questions

Can I appeal a denied CRA objection? Yes—within 90 days, you can appeal directly to the Tax Court of Canada.
Do I need a lawyer for a Tax Court appeal? It’s strongly recommended. Mackisen’s CPA–tax lawyer team manages the process seamlessly.
Can CRA collect during the appeal? No—collection actions are suspended while your appeal is under review.
What if 90 days have passed? Mackisen can file for an extension, citing exceptional circumstances or CRA delays.

Why Mackisen

At Mackisen CPA Auditors Montreal, we take denied objections personally—because they’re often wrong. Our dual team of accountants and lawyers builds appeals that the CRA can’t ignore and the Tax Court respects. We defend your rights, your reputation, and your finances with precision and persistence.

We don’t just reopen your case—we rewrite your outcome.

Call Mackisen CPA Auditors Montreal today for your 2025 CRA Objection Denial Appeal Consultation. The first meeting is free, and your protection starts immediately.