Can I object to a CRA assessment after the deadline?
Not as of right. Inside the objection period the assessment is simply disputed. Outside it, the objection is no longer available and the remaining routes differ in kind: an application to extend the time to object, which has its own conditions, or taxpayer relief, which addresses penalties and interest rather than whether the assessment is correct. Neither is a substitute for having objected. That is why this deadline is the most consequential date in Canadian tax dispute work, and why an assessment you disagree with should be diarised on the day it arrives rather than after advice is taken.
Does filing an objection stop the CRA from collecting?
It changes collection, and not in the same way for everyone. On ordinary files an objection generally holds collection of the disputed amount while the objection is considered. Large-corporation files are treated differently, with part of the disputed amount remaining collectible in spite of the objection. That distinction matters when planning cash, because a corporate group can object entirely properly and still receive a demand. Interest also continues to run on whatever is ultimately owed. An objection defers the collection question rather than removing it, and it is worth knowing which side of that line your file sits on before filing.
How much detail should a notice of objection contain?
More than most people put in it. The objection states the facts, the issues in dispute and the relief sought, and those three headings do real work. The facts are what you will be held to. The issues define what is being reconsidered. The relief tells the officer what outcome you are actually asking for. It is also the record an appeal is later framed from, so a thin objection is not a neutral starting point, it is a weak one. Writing it as though a judge will read it is the right posture even when the file settles long before that.
Is an objection the same as asking the CRA to fix a return?
No, and confusing them costs the deadline. A request to adjust a return asks the CRA to change something you reported, administratively, where there is no real disagreement. An objection disputes an assessment the CRA has made, formally, and it is the step that preserves a right of appeal. If an adjustment request is refused and the objection period has closed in the meantime, the straightforward route has gone and what is left is harder. Where there is any genuine disagreement about the assessment, object, and pursue the administrative correction alongside it if that looks quicker.
What happens after I file a notice of objection?
An appeals officer independent of the auditor reconsiders the assessment on the record and on anything further you provide. The file then ends in one of a few ways: the assessment is confirmed, it is reassessed in whole or in part, or the matter resolves on a narrower basis than either side started from. Whichever it is, the confirmation or reassessment is the document appeal timelines run from, so it should be read for its date as carefully as for its conclusion.
Can I add new arguments later if my objection was brief?
Sometimes, and it is not something to build a strategy on. The objection is the record an appeal is framed from, and an issue that surfaces for the first time late in the process invites the obvious question about why it was not raised when the facts were fresh. Ordinary files have more latitude here than large corporations, whose objections are expected to identify the issues and the relief sought with precision. The practical rule is the same either way: identify every issue you might want reconsidered while the objection is being drafted, including the ones you expect to abandon.
What happens if I have not filed for several years?
Missed years are handled as one package, not one at a time, because the route chosen for the first year determines the relief available for the rest. Each country has a disclosure or relief programme with its own conditions, and entering the right one — before the authority contacts you — is usually what keeps penalties down. Filing quietly outside a programme forfeits that protection. See catching up on missed returns.
Is "fund transfer pricing" the same thing as transfer pricing?
No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.
