Understanding CRA’s Appeal Process Timeline: How Long Does a Dispute Take? – A Complete Guide by a Montreal CPA Firm Near You

Introduction

Filing a Notice of Objection is only the first step in disputing a CRA reassessment. Many taxpayers are shocked to learn that CRA’s appeal process can take months—or even years—depending on the complexity of the dispute, the workload of CRA Appeals officers, and whether the case proceeds to Tax Court. Understanding how long CRA’s appeal process takes helps you plan financially, avoid unnecessary stress, and ensure your rights are protected throughout the appeal. This guide explains each stage of the CRA Appeals timeline, what to expect, and how to accelerate your dispute when possible.

Legal and Regulatory Framework

CRA’s objection and appeal process is governed by the Income Tax Act, Excise Tax Act (for GST/HST), and the Tax Administration Act (Quebec). Taxpayers must file a Notice of Objection within 90 days of receiving a Notice of Reassessment. CRA Appeals must conduct an independent review, separate from the audit division. If CRA does not resolve the objection within legislated timeframes, taxpayers may escalate the matter to the Tax Court of Canada. Collections for most income tax debts are paused during the objection stage, but GST/HST and payroll debts are not.

Key Court Decisions

In Hickman Motors v. Canada, the Supreme Court emphasized that CRA Appeals must independently review disputes rather than rubber-stamp audit findings. In LeBlanc v. Canada, CRA’s prolonged delays were criticized, demonstrating the importance of timely resolution. In Farm Business Consultants v. Canada, procedural fairness in objection handling was reinforced. These cases highlight that CRA must respect timelines and objectivity.

Stages of the CRA Appeals Timeline

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

The timeline begins the day CRA receives your objection. The objection must outline why CRA’s reassessment is incorrect and include supporting documents.

Stage 2: CRA Acknowledgement (2–6 weeks)

CRA sends a confirmation letter acknowledging receipt. Collections are paused (for income tax only).

Stage 3: File Assignment to Appeals Officer (4–12 months)

The file waits in queue until an Appeals Officer is assigned. This is often the longest waiting period.

Stage 4: Review and Requests for Information (1–4 months)

The Appeals Officer reviews audit notes, taxpayer evidence, legislation, and jurisprudence. They may request additional documents or clarifications.

Stage 5: Negotiation or Reconsideration (1–3 months)

The Appeals Officer may:

• Agree with the taxpayer (reassessment reduced or cancelled)

• Agree partially

• Confirm the auditor’s decision
  Many disputes settle at this stage.

Stage 6: Notice of Confirmation or Notice of Reassessment (Final Decision)

CRA issues:

• Notice of Confirmation (CRA stands by their reassessment), or

• Notice of Reassessment (CRA adjusts your taxes based on Appeal findings).

Stage 7: Appeal to Tax Court (if needed) (6–36 months)

If you disagree with CRA’s final decision, you may file a Notice of Appeal with the Tax Court of Canada. Tax Court timelines vary:

• Informal Procedure: 6–12 months

• General Procedure: 12–36+ months
  Most cases settle before reaching trial.

How Long CRA Appeals Usually Takes

Typical timelines:

• Simple objections: 3–9 months

• Moderate complexity: 9–18 months

• Complex cases (GST/HST, real estate, payroll, business income): 18–36 months
  Cases that move to Tax Court may take several years.

Factors That Affect the Timeline

• Complexity of the case

• Amount of evidence provided

• Whether CRA requires additional documents

• Workload of Appeals Officers

• Whether CRA considers the issue high-risk

• Whether GST/HST or payroll is involved

• Whether legal arguments must be reviewed
  Organized, well-documented objections move faster.

How to Speed Up Your Objection

Provide complete documentation upfront, respond quickly to CRA requests, avoid emotional arguments, organize evidence professionally, hire a CPA experienced in objection writing, and ensure the objection is legally grounded. Poorly written or incomplete objections delay the file significantly.

What Happens to Collections During the Appeal?

For income tax disputes, CRA collections are paused until Appeals makes a decision.
For GST/HST and payroll disputes, collections continue, and CRA may garnish or freeze accounts unless payment arrangements are negotiated.

When to Escalate to the Tax Court

If CRA delays unreasonably or makes an unfair decision, you may proceed to Tax Court after:

• 90 days without a CRA response, or

• Receipt of a Notice of Confirmation.
  Tax Court provides an independent ruling free from CRA bias.

Mackisen Strategy

At Mackisen CPA Montreal, we prepare strong, evidence-driven objections to reduce CRA timelines and maximize success. We organize all documentation, challenge CRA’s assumptions, cite legislation and jurisprudence, negotiate with Appeals Officers, escalate when needed, and communicate with Collections to minimize financial pressure during the dispute.

Real Client Experience

A Montreal family resolved a medical claim objection in four months due to our well-organized submission. A contractor overturned a GST reassessment after we filed a strong legal argument and documentation package. A corporation avoided escalation to Tax Court through negotiation with CRA Appeals. A landlord resolved a capital-vs-repair dispute after an eight-month appeals process.

Common Questions

How long does a typical appeal take? 6–24 months. Can CRA delay indefinitely? No—Tax Court provides an escape path. Do I pay during an objection? Not for income tax, but yes for GST/HST and payroll unless negotiated. Can a strong objection speed things up? Absolutely.

Why Mackisen

With more than 35 years of combined CPA experience, Mackisen CPA Montreal ensures your CRA appeals are handled with clarity, strategy, and legal precision. We protect your rights, manage timelines, and fight for a fair resolution every step of the way.