Understanding CRA’s Appeal Process Timeline: How Long Does a Dispute Take?

Introduction

Tax disputes with CRA do not resolve overnight. Once you file a Notice of Objection, your file enters the CRA Appeals Division — a completely separate branch from CRA Audit and Collections. The Appeals process can take months to several years, depending on the complexity of your issue, CRA workload, evidence quality, and whether the file escalates to Tax Court. Understanding the CRA appeal timeline saves you stress, helps you plan financially, and ensures you don’t miss critical deadlines. This guide explains exactly how long each stage takes and what to expect from CRA Appeals.

Why CRA Appeals Takes So Long

CRA Appeals handles tens of thousands of objections every year, involving:
income tax
GST/HST
payroll
real estate
crypto
foreign reporting penalties
small business audits
director’s liability
Appeals Officers must independently review each case, analyze evidence, apply legislation, challenge audit assumptions, and prepare formal decisions. The process is time-consuming — and deadline-driven.

Stage 1: Filing a Notice of Objection (Day 0)

You must file the objection:
within 90 days of the Notice of Reassessment
or within one year + 90 days through an extension request
Once filed, collections on income tax stops immediately. (Collections does NOT stop for GST/HST or payroll.)

Stage 2: Acknowledgment Letter (2–12 weeks)

CRA sends a letter confirming receipt of your objection. This does not mean the file is being reviewed — only that it has been logged.

Stage 3: Waiting Period Before Review (3–18 months)

Most objections wait months before an Appeals Officer is assigned. The timeline depends on:
region
complexity
volume of objections
Appeals prioritizes:
low-income taxpayers
hardship cases
death of a taxpayer
files involving time-sensitive credits

Stage 4: Assignment to an Appeals Officer (6–24 months)

Once assigned, the Appeals Officer:
reviews the full audit file
reviews your evidence package
requests additional documentation
analyzes legislation and case law
Contacts you or your representative for clarification.

How long this stage lasts

simple issues: 2–4 months
medium complexity: 6–12 months
high complexity (crypto, real estate, business income): 12–24+ months

Stage 5: Proposal Letter (optional)

Before issuing the official decision, the Appeals Officer may send a proposal outlining their position and giving you a chance to respond. You typically have 21–30 days to reply.
Responding thoroughly increases your chance of overturning CRA’s assumptions.

Stage 6: Appeals Decision (1–36 months after filing)

Appeals issues a:
Notice of Confirmation (CRA stands by the reassessment)
Notice of Variation (partial win)
Notice of Reassessment (win — CRA changes its position)
Total duration:
simple cases: 3–9 months
medium cases: 9–18 months
complex cases: 18–36 months

Stage 7: Tax Court of Canada (if required)

If you disagree with Appeals’ decision, you may appeal to Tax Court:
Informal Procedure: 6–18 months
General Procedure: 1–3+ years
Tax Court is independent and often overturns CRA assumptions.

How to Speed Up the CRA Appeal Process

submit a complete, organized objection
provide evidence proactively
respond quickly to CRA requests
avoid emotional or vague explanations
retain a CPA to manage communication
request priority processing if:
financial hardship
CCB/GST impacted
taxpayer is elderly or ill
Your file moves faster when it is professionally prepared.

When CRA Appeals May Delay Your Case

missing documents
incomplete objection
multiple tax years
GST/HST appeals (longer queues)
crypto or real estate files (complex)
queue backlogs
If your objection is weak or unclear, delays increase.

Important Rights During the Appeals Process

collections frozen on income tax
right to representation
right to submit evidence
right to request auditor notes
right to escalate to Tax Court
These rights protect you while CRA reviews the dispute.

When CRA Appeals Reaches Out

Appeals contacts you when:
they need additional information
they want clarification on evidence
they are preparing a proposal
they require updated statements or logs
A CPA ensures responses are accurate and strategically protective.

What Happens If Appeals Never Responds

After 90 days of no action, you may escalate directly to Tax Court. Most taxpayers don’t know this — but it is legally valid under the Tax Court of Canada Act.

After the Appeal: What Comes Next?

If you win:
CRA issues a new assessment
refunds or credits may be paid
interest is recalculated
If you lose:
you can pay, negotiate payment plans, or apply for Taxpayer Relief
OR:
appeal to Tax Court for further review

Mackisen Strategy

At Mackisen CPA Montreal, we prepare litigation-grade objections, organize evidence, respond strategically to CRA requests, challenge audit assumptions, and escalate files to Tax Court when necessary. Our structured approach shortens timelines and increases success rates.

Real Client Experience

A Montreal landlord resolved a reassessment in 7 months through a strong objection package. A contractor overturned a GST audit after 11 months. A crypto investor avoided a 2-year wait by escalating early to Tax Court. A business owner had penalties removed after a well-prepared proposal response.

Common Questions

How long do CRA objections take? 3–36 months. Does filing an objection stop collections? Yes for income tax. Do I need a CPA? Strongly recommended. Can I push CRA to act faster? Yes in hardship cases. Is Appeals independent? Yes, but still part of CRA.

Why Mackisen

With more than 35 years of combined CPA experience, Mackisen CPA Montreal helps taxpayers navigate CRA’s appeal process with professional preparation, strategic communication, and courtroom-ready documentation — ensuring your case receives fair, timely, and accurate review.