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Tax Objection

Have you been audited by the Canada Revenue Agency (CRA) or received an Assessment without prior communication? You are not alone, and you do have options!

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The results of an income tax audit are finalized when the CRA issues a Notice of Reassessment. From the date on the reassessment, you have 90 days to file a Notice of Objection, signaling your disagreement and intent to dispute the findings. If you miss this deadline, you can request an extension within 12 months of the expiration.

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Once the Notice of Objection is filed, a CRA appeals officer will contact you within 6 to 9 months. For income tax reassessments, all legal and collection actions are suspended. For trust fund assessments (GST/HST or Source Deductions), we will negotiate a nominal repayment plan to avoid collection or legal action during the dispute.

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It's crucial to consult a tax professional during this interim period to represent your interests. Our role involves reviewing the books and records examined by the CRA auditor to identify discrepancies, errors, and incorrect application of the law. A Tax  lawyer at Wealthbees will then prepare written representations based on law and fact. When the Appeals Officer contacts us, we submit our findings for review.

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The Appeals Officer may:

  • Vacate the reassessment, agreeing with the taxpayer.

  • Vary the reassessment, accepting some arguments and issuing a new reassessment.

  • Confirm the reassessment, rejecting the taxpayer’s arguments.

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If the reassessment is varied or confirmed, you can still appeal to the Tax Court of Canada.

The CRA may also issue Notices of Assessment without first auditing a taxpayer or if you do not respond to their audit questions. These include:

  • Net Worth Assessments

  • Notional / Arbitrary Assessments

  • Trust Examinations

  • Third Party Assessments for Directors Liability

  • Third Party Assessments under Section 160 of the Income Tax Act

If you are facing any of these assessments or audits, contact Wealthbees.

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