Who can file Form T400A?
Any taxpayer who disagrees with a Canadian assessment or reassessment. That is broader than it sounds. It takes in a determination that you were resident for a year you regard as a non-resident year, a penalty charged on a foreign-reporting form, and the ordinary case of income the agency says you had and you say you did not. The form is the formal objection, and filing it is what starts the appeals process rather than continuing a conversation with the assessor. What matters is that you are the person assessed, or acting for them, and that you are inside the objection deadline.
Can I object if my assessment shows no tax owing?
Yes. The right to object attaches to the assessment, not to a balance, and some of the assessments most worth objecting to carry no tax at all: a residency determination, or a penalty on a foreign-reporting form where the income itself produced nothing payable. The exposure here is decided by facts rather than by tax owing, which is why a nil position does not remove it. If you leave a nil assessment unobjected because nothing is payable, you are accepting the finding of fact underneath it, and that finding can matter in the years that follow.
Can a non-resident object to a Canadian assessment?
Yes, and a residency determination is one of the things this objection exists for. Where the agency has assessed you as resident for a year you treat as a non-resident year, the objection is where that is argued, with the facts about ties, presence and intention set out in support of it. Living outside Canada takes nothing away from the right to object. It does not by itself extend the deadline either, which is the practical problem for anyone whose post reaches an overseas address slowly, or reaches an old address first.
What happens if I miss the T400A objection deadline?
The deadline is the whole ball game. Filed inside it, the assessment is under objection and the dispute proceeds on its merits. Miss it and two narrower routes remain: an application to extend the time for objecting, which has to explain why the objection was not made in time, and a request for relief, which can reach penalties and interest but never the tax. So a missed deadline does not always end the matter, but it moves you from arguing about whether the assessment is right to arguing about whether you should be heard at all.
Does filing an objection stop the CRA collecting?
Objecting changes the collection position, and that is the main reason the deadline matters when the amount is large. It is not a blanket stop and it is not uniform, because what happens next depends on the taxpayer and on the type of amount assessed, so it is worth having the answer in writing on your own file rather than assuming it. Two things are worth separating in any case. An assessment under objection sits in a different posture from one that is merely unpaid, and interest continues to accrue on an unpaid balance regardless, so disputing and paying are not alternatives.
Can I object to a foreign reporting penalty?
Yes. Foreign-reporting penalties are one of the assessments this objection is squarely for, and they are worth objecting to precisely because they are charged by reference to the form and the delay rather than to the tax, so the charge can be substantial on a year that produced nothing payable. The objection is where the facts that bear on the charge go: what was filed, when, what the taxpayer knew and when they knew it, and what they did once they knew. That is a different argument from asking for the penalty to be forgiven, and it belongs inside the deadline.
How do families with assets in two countries handle inheritance?
With paperwork built for both systems rather than one. In practice that means wills that work where each asset actually sits, an executor with authority a foreign bank or land registry will accept, clearance certificates before the estate distributes so the executor is not left personally exposed, and an estate tax exposure calculation done while the person is alive and can still act on it. Doing it afterwards costs more and forecloses most of the options. See cross-border wills and trusts.
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.
