Steps of Challenging CRA Audit Assessments
So you had a CRA Audit and Assessment. What can you do to challenge the CRA Audit results? Can a Chartered Professional Accountant help? There are specific steps and timelines when objecting to a CRA Audit and Assessment. A Chartered Professional Accountant is well suited to help you with gathering evidence and presenting your case.
This article doesn’t set out your obligations during a CRA Audit or how you should approach it. It provides an outline of the steps you or a Chartered Professional Accountant takes to challenge a (re)assessment.
Once you received a Notice of (Re)Assessment, time starts ticking. The Income and the Excise tax acts both give you 90 days to object. The time starts running on the day that the Notice of Assessment is sent and not the day you received the notice. The CRA provides a form you can use to file your objection (T400A for income tax and GST159 for GST/HST). You don’t have to use the form for an Income Tax objection but you do for a GST/HST objection.
You file your objection with the CRA, addressed appropriately, and include the reasons for the objection and all relevant facts. The legislation is complex. Knowing what reasons are appropriate and what facts are relevant is a difficult task that varies with the CRA Audit findings. A Chartered Professional Accountant has the knowledge, skills, and experience to lead you through this maze.
If your objection is denied, you can either file a second level review or you can file an appeal to the Tax Court. You have 90 days from the CRA’s confirmation or determination. You can also go right to the Tax Court if the CRA doesn’t give you an answer within 90 or 180 days. A Chartered Professional Accountant can help you decide on the appropriate procedure and prepare the materials and arguments needed to succeed.
Disclaimer: Articles are for general information only and do not constitute tax advice. They cannot be relied upon.
Sam Faris is a Toronto-based Chartered Professional Accountant who practices as an independent consultant on high-level Canadian tax matters and handling disputes with CRA.He also published an article recently in the business magazine: HERE.