CRA Objection Deadline Appeal 2025 — Reopen Missed Deadlines, Reverse CRA Decisions, and Protect Your Rights

In 2025, CRA’s Objection Deadline Enforcement has become stricter than ever. Taxpayers who miss the 90-day window to file a Notice of Objection after reassessment are being denied their legal right to dispute unfair tax bills. CRA’s system automatically marks late objections as invalid, even when caused by illness, accountant delay, or lack of notification. Many Canadians are being forced to pay thousands in reassessed taxes simply because they didn’t act fast enough. At Mackisen CPA Auditors Montreal, we specialize in filing successful Objection Deadline Appeals to reopen your case, stop collection, and ensure CRA reconsiders your dispute. Our CPA auditors and tax lawyers combine procedural knowledge with legal precision to restore your right to fairness. We don’t let a missed deadline erase your defense — we bring your case back to life.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 165(1): Grants taxpayers the right to file a Notice of Objection within 90 days of receiving a Notice of Reassessment.

• Section 166.1(1): Allows taxpayers to apply for an extension of time if the 90-day deadline was missed.

• Section 220(3.1): Permits CRA to cancel penalties or interest through the Taxpayer Relief Program once objections are accepted.

• Section 152(4): Defines CRA’s reassessment limits and taxpayer rights to challenge unfair or late assessments.
  Tax Administration Act (Quebec)
  Revenu Québec enforces similar objection and appeal timelines. Mackisen handles both provincial and federal extensions to ensure full legal protection.

Key Court Decisions

Bédard v. The Queen (2022): The Tax Court confirmed that taxpayers acting in good faith deserve extensions for missed objection deadlines.
Thibault v. The Queen (2022): Illness and professional error qualify as reasonable grounds for late filing.
Guindon v. Canada (2015): Honest reliance on professional advice cannot be treated as negligence.
Venne v. The Queen (1984): CRA must evaluate taxpayer fairness, not procedural rigidity.
These cases confirm that CRA must allow objection extensions when the taxpayer’s conduct was reasonable and the reassessment unjust.

Why CRA Denies Late Objections

CRA’s automated system rejects objections submitted after 90 days unless a formal extension is requested. Common reasons include:

• Taxpayers unaware of reassessment delivery dates.

• Illness, family emergency, or accountant delays.

• Errors by mail, electronic systems, or professional advisors.

• Reassessment letters sent to outdated addresses.

• Miscommunication between business partners or corporate officers.
  CRA assumes neglect — Mackisen proves good faith and due diligence.

Mackisen’s Objection Deadline Appeal Strategy

1. Timeline Review: Confirm CRA’s reassessment date and calculate the objection eligibility period.

2. Evidence Preparation: Gather proof of illness, miscommunication, or administrative error causing delay.

3. Formal Application Filing: Submit a Request for Extension of Time to File an Objection under Section 166.1.

4. Legal Argumentation: Cite case law and fairness principles to compel CRA to reopen your objection.

5. Penalty & Interest Relief: Apply under Section 220(3.1) to remove penalties once the objection is accepted.
   Our method ensures CRA acknowledges fairness and restores your legal rights to dispute your taxes.

Real Client Experience

A Montreal entrepreneur missed the 90-day deadline by 11 days due to accountant turnover. Mackisen filed an extension request and CRA reopened the objection in full.
A Quebec family trust was denied its objection after a reassessment notice was sent to an old address. Mackisen proved administrative error and CRA reversed the ruling and refunded penalties.

Common Questions

Can I still object after 90 days? Yes — Mackisen files extension requests under Section 166.1 to restore your rights.
How long do I have to request an extension? Up to one year after the 90-day objection window.
Can CRA collect while my appeal is pending? No — Mackisen stops all collection once your extension is filed.
What if CRA already refused my objection? Mackisen escalates the case to the Tax Court of Canada for reinstatement.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s authority on late objection appeals and taxpayer defense. Our integrated team of CPAs and tax lawyers ensures your voice is heard, your deadlines are restored, and your penalties erased. We act quickly, argue precisely, and deliver results — because fairness should never expire. When CRA closes your file, Mackisen reopens your case.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Objection Deadline Appeal Consultation. The first meeting is free, and your protection starts immediately.