Filing a Notice of Objection Step-by-Step

Introduction
Understanding filing a notice of objection step-by-step is essential for any taxpayer facing a CRA reassessment or an assessment from Revenu Québec. A Notice of Objection is your formal legal right to dispute a tax decision you believe is incorrect. It stops collections (for income tax), protects your rights, and forces CRA or ARQ to review your case independently of the original auditor. Many taxpayers lose their right to fight assessments because they do not know the proper deadlines, documentation requirements, or procedural steps. This guide explains filing a notice of objection step-by-step so you can defend yourself correctly and effectively.

Legal and Regulatory Framework
Filing a notice of objection step-by-step is governed by:

• the Income Tax Act
• the Excise Tax Act (for GST/HST disputes)
• Québec’s Tax Administration Act (for QST/income tax objections)
• CRA and ARQ administrative dispute-resolution policies
• relevant case law and procedural fairness standards

A Notice of Objection is required when:

• CRA issues a Notice of Reassessment
• CRA denies credits, deductions or ITCs
• CRA adds unreported income or taxable benefits
• ARQ (Revenu Québec) challenges provincial filings
• payroll reassessments impose penalties
• GST/HST or QST returns are adjusted

Knowing filing a notice of objection step-by-step protects taxpayers from unfair assessments.

Step 1: Read Your Reassessment Carefully

Before filing, you must understand:

• what CRA or ARQ changed
• why they believe the change is required
• how much tax, penalties and interest were added
• which tax years are affected
• whether the auditor misunderstood or ignored key information

Most reassessments contain simplifications or errors. Identifying these is critical in filing a notice of objection step-by-step.

Step 2: Confirm Your Deadline

You must file a Notice of Objection within:

• 90 days from the date of the Notice of Reassessment
OR
• 1 year after the filing deadline for that tax year — whichever is later

Québec also uses a 90-day deadline.

Missing deadlines severely limits your rights and may require special extension applications.

Step 3: Gather All Evidence and Documentation

The strength of your objection depends on documentation.
Gather:

Income Documentation

• invoices, bank statements, e-transfers
• rental agreements
• T4, T5, T5018 slips
• gig-economy platform statements (Uber, Airbnb, PayPal, Stripe)

Expense Documentation

• original receipts
• contracts
• mileage logs
• proof of payment
• GST/HST/QST invoices supporting ITCs/ITRs
• home-office calculations
• payroll records

Real Estate Documentation

• purchase and sale agreements
• assignment contracts
• occupancy evidence
• renovation documents

Proper evidence is essential in filing a notice of objection step-by-step.

Step 4: Draft a Clear, Professional Notice of Objection

Your objection must include:

• taxpayer information
• reassessment details
• a clear explanation of why CRA or ARQ is wrong
• supporting facts
• references to the Income Tax Act or Excise Tax Act (if relevant)
• legal arguments when appropriate
• referenced attachments and documentation

For CRA, file via:

• My Account / My Business Account
• Form T400A (paper submission)

For ARQ (Revenu Québec):

• MR-93.1 Objection form
• Online Services Portal submission

This is the most important step in filing a notice of objection step-by-step.

Step 5: Submit the Notice of Objection Before the Deadline

Filing on time guarantees your right to independent review.

• CRA’s Appeals Division takes over the file
• ARQ’s Opposition Division reviews Québec objections

Collections for income tax are paused while the objection is open (not GST/QST).

Step 6: Respond to Appeals Officer Requests

Once the objection is assigned:

• an Appeals Officer may request additional documentation
• they may ask for explanations
• they may propose adjustments
• they may request negotiation meetings

This stage is where most objections succeed or fail.

Responding professionally is critical.

Step 7: Receive the Final Decision

CRA or ARQ will issue:

• a Notice of Confirmation (they uphold their reassessment), or
• a Notice of Reassessment reducing or cancelling the original amount

If the result is unfavourable, you may escalate to the Tax Court of Canada (for CRA) or the Court of Québec (for ARQ).

Key Court Decisions

Several rulings clarify filing a notice of objection step-by-step:

• CRA must review objections independently of auditors
• taxpayers bear the burden of proving entitlement to deductions
• CRA cannot arbitrarily deny evidence
• reassessments can be overturned if documentation supports the taxpayer
• procedural fairness must be respected throughout
• Québec courts enforce strict objection deadlines

These court decisions reinforce taxpayers’ rights during the objection process.

Why CRA and ARQ Reassess Taxpayers

Objections usually arise after reassessments involving:

• missing receipts
• business losses denied
• GST/HST or QST ITCs denied
• rental income or real estate errors
• vehicle or travel expense disputes
• payroll errors
• crypto reporting issues
• e-commerce income mismatches
• unreported deposits
• principal residence exemption disputes

Understanding these issues is essential to filing a notice of objection step-by-step effectively.

Mackisen Strategy

Mackisen CPA provides full litigation-ready objection support:

• reviewing reassessments for auditor errors
• reconstructing missing records
• drafting legal-quality Notice of Objection submissions
• referencing tax legislation and case law
• managing all communication with CRA and ARQ
• negotiating with Appeals Officers
• filing fairness relief requests for penalties and interest
• escalating to Tax Court where necessary
• protecting taxpayer rights at every stage

Our structured process dramatically increases the chances of a successful objection.

Real Client Experience

Examples of how Mackisen resolved client objections:

• A freelancer had vehicle expenses denied. We filed a detailed objection with reconstructed mileage and reversed the reassessment.
• A Québec landlord was denied the New Residential Rental Property Rebate. Mackisen proved rental intent and won the appeal.
• A self-employed consultant was reassessed for missing PayPal income. We reconciled deposits and reduced taxes owed by 85%.
• A real estate flipper was taxed as a business instead of capital gains. We negotiated a partial capital-gain treatment.
• A corporation faced payroll penalties for QPP/QPIP errors. We corrected filings and removed penalties through objection.

These examples show why professional representation matters in filing a notice of objection step-by-step.

Common Questions

• Does filing an objection stop interest?
No—interest continues until resolved.

• Does filing an objection stop collections?
Yes—for income tax; no for GST/QST.

• Can I object after the deadline?
Possibly, but only with a written extension request and valid reasons.

• How long do objections take?
From 3 months to 18+ months.

• Can CRA deny my objection without review?
No—they legally must review it independently.

• Can I escalate to tax court?
Yes—if unsatisfied with the decision.

Why Mackisen

With more than 35 years of combined CPA experience, Mackisen CPA Montreal helps taxpayers dispute unfair assessments while staying fully compliant. Whether you're filing a notice of objection step-by-step or challenging a reassessment already in progress, our expert team provides full representation, evidence preparation, legal argumentation and strategic defense to protect your rights and minimize tax exposure.