Filing A Notice Of Objection 2025

When you receive a CRA Notice of Reassessment, you have only 90 days to fight back—and filing a Notice of Objection is your first and most important line of defense. In 2025, CRA and Revenu Québec are enforcing reassessments faster than ever using AI-driven systems, and missing your objection deadline can make their decision final—even if it’s wrong. Once that window closes, you lose the right to appeal, and CRA can begin collecting immediately.

A Notice of Objection is not just paperwork—it’s a formal legal challenge to CRA’s decision. It must include the exact facts, arguments, and legislation supporting your position. One missing detail can cause your objection to be rejected or delayed for months. At Mackisen CPA Auditors Montreal, we build strong, fully documented objections that stand up to CRA scrutiny. We combine accounting precision with legal expertise to reverse unfair reassessments and protect your financial rights.

Legal and Regulatory Framework

Income Tax Act (Canada)
Section 165(1): Grants taxpayers 90 days to file a Notice of Objection after receiving a Notice of Assessment or Reassessment.
Section 166.1: Outlines appeals to the Tax Court of Canada if objections are denied.
Section 161(1): Interest accrues daily on unpaid balances during disputes.
Section 220(1): Allows CRA to continue collecting disputed amounts unless a formal objection is filed.

Tax Administration Act (Quebec)
Requires Quebec taxpayers to file a separate Notice of Objection with Revenu Québec within 90 days, in addition to federal filing.

Mackisen prepares and files both federal and Quebec objections with all supporting evidence, legal arguments, and compliance documentation—protecting you from penalty and interest escalation.

Key Court Decisions

Venne v. The Queen (1984): Failure to file an objection within 90 days renders the reassessment final and binding.
Guindon v. Canada (2015): CRA penalties are enforceable unless successfully challenged through objection or appeal.
Jordan v. The Queen (2009): Interest continues to accumulate during objection unless CRA grants relief.

These precedents make one thing clear: you must act quickly, precisely, and professionally.

Why Filing a Notice of Objection Matters

A Notice of Objection is your legal opportunity to dispute CRA’s decision before it becomes permanent. It tells the CRA Appeals Division why their reassessment is incorrect—and it stops collection activity on disputed amounts until a decision is made.

Common Reasons to File a Notice of Objection in 2025:

• CRA denied deductions or expenses (business, moving, or home office claims).

• CRA added unreported income (rental, investment, or side income).

• CRA disallowed RRSP, FHSA, or charitable donation claims.

• CRA assessed penalties or interest unfairly.

• CRA made errors in applying tax treaties or foreign income rules.

Without a properly structured objection, your right to challenge CRA disappears—and interest on the disputed amount grows every day.

Mackisen’s CRA Objection and Appeal Strategy

1. Reassessment Review: Analyze CRA’s calculations, assumptions, and legal justifications.

2. Evidence Compilation: Gather receipts, contracts, and financial data to substantiate your position.

3. Legal Argumentation: Draft a detailed Notice of Objection citing the correct provisions of the Income Tax Act.

4. Filing and Representation: Submit objections within the 90-day limit and liaise directly with CRA or Revenu Québec appeals officers.

5. Appeal and Negotiation: If unresolved, escalate to the Tax Court of Canada with full representation by our tax lawyers.

Our process ensures your objection is bulletproof, timely, and positioned for success.

Real Client Experience

A Montreal engineer was reassessed for $27,000 after CRA disallowed moving expenses. Mackisen filed a Notice of Objection supported by documentation and reversed the entire reassessment in 10 weeks.
A small business owner faced CRA penalties for alleged underreporting. Mackisen appealed, presented ledger evidence, and reduced the penalty to $0.

Common Questions

How long do I have to file a Notice of Objection? 90 days from the date printed on your reassessment. Mackisen handles all filings before the deadline.
Do I have to pay while my objection is under review? No—CRA collection actions are paused once an objection is officially filed.
Can I object to old reassessments? Possibly, through an application for late acceptance (up to one year). Mackisen can file this for you.
What happens if CRA denies my objection? We can escalate immediately to the Tax Court of Canada or negotiate through settlement review.

Why Mackisen

At Mackisen CPA Auditors Montreal, we treat every objection as a legal defense—not a formality. Our CPA auditors and tax lawyers collaborate to build airtight arguments, backed by evidence, jurisprudence, and legislative precision. We protect your rights, minimize penalties, and ensure your case is heard fairly.

We understand how stressful CRA disputes can be—but with Mackisen, you’ll never face them alone. We act quickly, confidently, and decisively to protect what’s yours.

Call Mackisen CPA Auditors Montreal today for your 2025 Notice of Objection Filing Consultation. The first consultation is free, and your defense begins immediately.