We solve serious CRA tax problems

The CRA Isn’t Always Right. Here’s How to Dispute Your Tax Assessment

Let’s kill the myth: the Canada Revenue Agency (CRA) is not an infallible financial machine. It’s made up of people, and humans make mistakes. And when they do? You have every right to challenge it strategically, clearly, and with professional help from an expert who specializes in resolving CRA disputes.

This isn’t about becoming an outlaw. It’s about protecting yourself from errors that can cost you thousands. When the CRA gets it wrong, you’re the one left holding the bill.

Let’s fix that.

What Triggers a CRA Tax Assessment (and Why It Might Be Wrong)

If your mailbox just got hit with a thick envelope from the CRA, or your inbox notified you of impending CRA doom, and your blood pressure spiked? You’re not alone.

The CRA doesn’t assess taxes manually anymore. Most assessments are triggered by algorithms that detect patterns, irregularities, or “anomalies.” That could mean:

  • You reported income that doesn’t match a T4 or T5 slip 
  • You claimed a larger-than-normal deduction (even if it was legit) 
  • You had self-employment income 
  • You filed late or amended a return 
  • You claimed home office or vehicle expenses that are higher than the average for your industry 
  • You’re in a high-risk category, like digital creators or small business owners 

These are all CRA audit triggers. And while some of these flags are reasonable, they aren’t always accurate. The system doesn’t know your life. It doesn’t know context. It just sees a number it doesn’t like, and spits out an assessment.

The problem? It’s up to you to prove them wrong.

Common CRA Errors That Could Cost You Thousands

CRA analysts and tools process data quickly, but context can get lost. And when context is missing, errors happen. Here are some of the most common:

  • Legitimate business expenses were rejected because receipts weren’t descriptive enough 
  • RRSP contributions applied to the wrong year 
  • Tax credits missed entirely 
  • Self-employment income double-counted 
  • Foreign income wrongly taxed as domestic 
  • Misinterpretation of investment gains vs capital gains 

These aren’t small errors. These are the kinds of mistakes that turn into $5,000 reassessments and years of unnecessary stress. If you don’t know what to look for, you’ll pay for it.

Your Right to Push Back: Understanding the Notice of Objection

Let’s get legal for a minute.

When you receive a Notice of Assessment (NOA) and disagree with it, you don’t have to accept it. Your legal response is called a Notice of Objection.

This isn’t a complaint letter. It’s a formal tax form that tells the CRA: “I disagree, and here’s why.”

Important details:

  • Deadline. 90 days from the date on your assessment (not the day you opened it, not the day you cried in the shower) 
  • Format. You can file online via My Account/My Business Account, or use Form T400A 
  • Tone. Professional, factual, with clear evidence backing your position 

You need to be calm, direct, and organized. Emotional arguments won’t help you. Documentation will.

Once you file your objection, it gets reviewed by a CRA appeals officer, not the same person who issued the original assessment. That means you get a fresh set of eyes. Use the opportunity wisely.

Deadlines and Paper Trails: Timing Is Everything in Tax Disputes

Let’s break down the actual timeline:

  1. Notice of Assessment received 
  2. 90 days to file a Notice of Objection 
  3. CRA reviews your objection (this can take months) 
  4. If denied or unresolved, you have another 90 days to take it to Tax Court 

That’s it. Miss those deadlines and your options close like a door that locks behind you.

Now, about that paper trail. Keep everything. Every letter. Every email. Every phone call (with names, dates, and what was said). If the CRA changes reps, your records will be your only consistency.

Receipts? Organize them. Bank records? Match them to claims. Did you call the CRA and get verbal confirmation on something? Document it.

Going Beyond the Objection: Appeals Division and Tax Court Basics

So you filed your objection, and the CRA still says “no”? You’re not out of options.

Next up is the CRA Appeals Division. This is where things get real. You’re dealing with senior officials who are trained to reassess both the facts and how the CRA handled your objection.

At this stage, you need to:

  • Present your case clearly 
  • Include relevant case law or precedent (your tax pro can help) 
  • Stay persistent. Delays happen, but don’t let them drag on for years 

Still no dice? Then it’s Tax Court of Canada time.

Here’s the good news: most cases settle before you ever get to court. Just preparing to go that far often signals that you’re serious, and many CRA lawyers will recommend settling to avoid a legal mess.

When to Call in Reinforcements: Why Professional Representation Matters

You wouldn’t go to court without a lawyer. Don’t go to a tax battle without a seasoned tax consultant.

When the CRA challenges your return, it’s no longer just about filing. It’s about:

  • Interpreting the Income Tax Act 
  • Using financial language they respect 
  • Framing your case around CRA policy and precedent 
  • Negotiating, not pleading 

Professional representation gives you leverage. It also gives you protection. One wrong word on a call with a CRA agent can backfire. Pros know how to talk to them, and when not to.

You don’t need to fight alone. And you shouldn’t.

How Faris CPA Strategically Handles Tax Disputes (And Wins)

At Faris CPA, this is our bread and butter.

We don’t panic when clients come to us with a seemingly air-tight reassessment. We reverse-engineer the CRA’s logic and rebuild the case from the ground up.

Here’s how we do it:

  • Step 1. Audit the assessment for errors, assumptions, and omissions 
  • Step 2. Gather the correct documentation, timelines, and receipts 
  • Step 3. File a clear, deadline-safe Notice of Objection 
  • Step 4. Follow up with the CRA until it’s resolved 
  • Step 5. Escalate to appeals or Tax Court if needed. Our goal, however, is to always resolve cases in our clients’ favour without an escalation, and we have the track record to prove it. 
  • Step 6. Win, whether through settlement, reversal, or correction 

Whether you’re wondering how far back the CRA can audit you or you’re facing serious CRA tax audit penalties, we’ve seen it all. We’ve fought it all.

And we’ve won.

Real Case Scenarios: From Overturned Penalties to Settled Balances

Let’s talk receipts. Not the paper kind. The real-world results kind.

Case 1:
A Shopify seller got reassessed for over $40,000 due to “undeclared income.”
Problem? The CRA misclassified business deposits as personal gifts.
Outcome: Full reversal. No penalties. Client refunded.

Case 2:
A freelance web designer had their home office expenses and software subscriptions denied.
Outcome: We proved business usage and got the deductions approved.

Case 3:
A digital creator was hit with penalties for unfiled tax returns, even though they had submitted them via a third-party platform.
Outcome: Penalties removed. CRA acknowledged the submission error.

Case 4:
A small business owner panicked after making an honest mistake on a GST return and called us asking: “What happens if you make a tax mistake?”
Outcome: We filed a voluntary disclosure and adjusted the return. No penalties.

These aren’t rare wins. They’re daily ones.

What You Can Do Now to Strengthen Your Case

If your CRA assessment is wrong, don’t wait. Start here:

  • Get a complete copy of your Notice of Assessment 
  • Request your CRA account history and notes 
  • Compare your return to your assessment line by line 
  • Organize all supporting documents: bank statements, invoices, receipts 
  • Draft a clean explanation of your position; factual, not emotional 
  • Use online platforms like My Account or ReFile if there’s a clear fix 

If you’re unsure where to start, book a call. Even one consultation can stop a snowball of errors before it becomes an avalanche of debt.

What Happens After You File a Notice of Objection?

You wait, but not passively. Once your objection is filed, the CRA assigns an appeals officer. That can take weeks or months. While you wait:

  • Keep collecting supporting documents 
  • Review your original return again with fresh eyes 
  • Don’t engage in casual conversations with CRA agents about the case 

This isn’t idle time, it’s prep time.

Can You Still Amend Your Return After Getting Assessed?

Yes. If the issue is with your numbers, not theirs, you might benefit more from adjusting your return than objecting. Use this if:

  • You made a clerical or reporting error 
  • You forgot a credit or deduction 
  • The CRA actually assessed your return correctly based on wrong information you gave 

Start with adjusting your tax return here: T1-ADJ Guide

Should You Pay First, Then Dispute?

Short answer: it depends.

  • If you can afford it, paying upfront stops interest from snowballing 
  • If you win the dispute, you get refunded 
  • But if the amount is large, paying before resolving might create more financial stress 

Weigh this decision carefully with your rep.

What If the CRA Doesn’t Respond?

They might ghost you. Not intentionally, but possibly due to a backlog.

After 90 days with no decision, you have the right to take your case to Tax Court. It’s called a deemed denial. Don’t wait forever hoping they’ll get back to you.

CRA Language Barriers: What If English Isn’t Your First Language?

Misunderstandings can snowball into assessments. That’s why Faris CPA offers multilingual services in Arabic, French, Mandarin, and more.

If you received an assessment and don’t fully understand the wording or terminology, don’t guess. Ask us.

The CRA Might Not Care About Stress, But We Do

The CRA doesn’t generally consider personal stress or anxiety as part of a dispute. They care more about paperwork, numbers, and timelines.

We care about how it’s affecting your life, your sleep, and your work. That’s why we don’t just defend your numbers, we give you back your bandwidth.

The Truth About Penalties: Are They Negotiable?

Yes. CRA penalties can be challenged, reduced, or even cancelled. Especially if:

  • You made an honest mistake and fixed it quickly 
  • You were dealing with hardship (medical, financial, etc.) 
  • The CRA’s assessment was flawed to begin with 

It’s not guaranteed, but it’s possible. We’ve seen it.

Late Filing vs. Non-Filing: Know the Difference

  • Late filing means you submitted, just not on time 
  • Non-filing means they never received your return at all 

The consequences of unfiled tax returns are severe: automatic penalties, assumptions about your income, and often, aggressive audits. Avoid this spiral at all costs.

Digital Creators and the CRA: Why You’re Targeted

If you earn money on TikTok, YouTube, Etsy, or OnlyFans, you’re considered self-employed, and the CRA eyes you more closely.

They sometimes assume creators don’t report all income or inflate expenses. That’s not paranoia; it’s documented audit policy.

You need airtight records and a solid understanding of what you can and can’t claim. We help creators every week. This is our turf.

You Can Request CRA’s Internal Notes, And You Should

The CRA keeps a record of every interaction, internal memo, and case decision related to your file.

You can file an Access to Information Request to get those notes. Sometimes, they reveal major errors or unfair assumptions.

This move can change the game.

T1 vs T2 Disputes: Know What You’re Fighting

  • T1 = personal taxes 
  • T2 = corporate returns 

T2 disputes are more complex, with stricter documentation standards. If you’re incorporated and got reassessed, don’t wait; corporate audits escalate fast and hit harder.

Don’t Mix Personal and Business Accounts

If you’re self-employed and you use one account for both groceries and client payments, expect the CRA to challenge your deductions.

Clean separation = fewer arguments = stronger defence.

Keep Your Receipts, But Organize Them Like a Lawyer

Shoving everything into a shoebox won’t help you now. Receipts should be:

  • Dated 
  • Legible 
  • Matched to a category (travel, meals, home office) 
  • Linked to the work performed 

Digital records count, but only if they’re stored properly. The CRA won’t chase down your Dropbox.

Don’t Rely on Verbal CRA Advice

If you call the CRA and an agent says something helpful, amazing. But unless it’s in writing? It’s not binding.

If you’re ever given advice over the phone, immediately send a written follow-up confirming it. If they reply (even better), it becomes part of your file.

When the CRA Applies Interest Incorrectly

Interest charges are automatic, but not always accurate.

If the CRA applied interest to an incorrect balance or continued charging it after your payment, it’s disputable.

We’ve had entire interest charges wiped out with the right paperwork.

Overhead view of a person using a calculator and reviewing tax documents, with text that reads “Think the CRA Got It Wrong? Challenge Your Tax Assessment with Expert Support,” representing Faris CPA.Credit: Getty Images

Use This Checklist Before Filing an Objection

Quick self-audit before you hit “Submit”:

  • Is your objection within 90 days of the assessment? 
  • Do you have a copy of the NOA? 
  • Do you have documentation for every disputed point? 
  • Is your argument fact-based and clearly written? 
  • Did you check for typos or clerical errors? 

If any of these are missing, fix them first.

You’re Not a Tax Lawyer. You Don’t Need to Be

Tax law is complex for a reason: it wasn’t written for normal people. That’s why hiring someone who reads it for breakfast matters.

Our clients aren’t tax experts. They’re people who know when to call one.

What to Do If You Haven’t Filed Yet and You’re Panicking

First: breathe. Then:

  1. Pull your T-slips, receipts, and invoices 
  2. Get your past returns in order 
  3. Use our CRA tax audit support if you’re worried about triggers 
  4. File as soon as possible 
  5. Then worry about objections if needed 

Filing late is fixable. Filing wrong, however, can open a new can of worms.

Yes, You Can Win Against the CRA

We’ve said it before, but it needs its own headline.

This isn’t a rigged system. It’s just one stacked in favour of the prepared. If you have strategy, timing, receipts, and professional backup, you can win.

And we’ve got the client list to prove it.

Not Sure Where to Start? All You Have to do is Call

You don’t need to decide everything today. But one call can shift the weight off your shoulders. We’ll tell you if your case is winnable, how to move forward, and whether to fight or file.

It’s free. It’s confidential. And it could save you thousands.

CRA “Arbitrary Assessments” Are a Real Thing

If you don’t file, or they think you’re hiding something, the CRA can issue an arbitrary assessment: a best guess based on limited data. They are usually not accurate and use numbers that work against you.

Don’t ignore it. You can dispute them, and we’ve had plenty set aside when challenged correctly.

The CRA Might Reassess You Again. Be Ready

Even if you win your current objection, the CRA isn’t done forever. They can reassess future years. They can audit retroactively. (Wondering how far back they can go? It depends on whether they allege misrepresentation.)

Winning now doesn’t mean relaxing; it means preparing for next time. We’ll help you build that firewall.

Don’t Use TurboTax Screenshots as Evidence

We’ve seen it. Clients try to defend deductions with screenshots of DIY tax software entries.

Nice try, but no. The CRA needs receipts, contracts, or original T-slips. Your interface history won’t cut it. Use real, traceable, verifiable documentation. Always.

If You’re Being Audited, You’re Already Under the Microscope

Objection and audit timelines often overlap. If you’re being audited and you file an objection, assume everything you submit will be scrutinized.

This is not the time for guesswork or half-truths. Our CRA audit strategy is surgical, because this is where bad cases go to die or win.

Getting Ghosted by Your Accountant? It Happens

Plenty of clients come to us after getting reassessed and abandoned by the person who filed their return.

Here’s the truth: not all tax preparers are equipped to handle disputes. If your accountant disappears the moment the CRA shows up, call us. We pick up where they flake out.

The Bottom Line: Don’t Settle for the CRA’s First Word

The CRA’s assessment isn’t law. It’s just their take.

You have rights. You have time (if you act fast). And you have backup, if you ask for it.

Faris CPA is known for sharp, strategic tax dispute support across Canada. We serve creators, consultants, small business owners, and everyday Canadians who just need a fair shake. We offer virtual services, multilingual support, and real solutions.

If you’re ready to challenge a tax assessment that doesn’t feel right, we’ll help you get it corrected. You don’t need to roll over.

You need to push back. Professionally and effectively.

About the Author

pro-tip

Pro Tip

ACCESSING THE SMALL BUSINESS DEDUCTION IN YOUR BUSINESS

The Small Business Deduction gives businesses a tax deduction on the first $500,000 of income. This saves an eligible corporation around up to $50,000 in income taxes. There are a number of conditions that have to be met to be eligible for this deduction.

I was referred to Sam Faris by a family member who highly recommended him to deal with my CRA audit matter which has been ongoing for almost 2 years. Considering that this was a sensitive issue, I needed to make sure that Sam would be the right fit to handle my case. I requested an in-person meeting. I met with Sam for more than 2 hours. He went through CRA proposal letter and immediately identified the weaknesses in CRA’s calculations. He immediately advised on the best approach to dispute this proposal and provided a time line when he will submit the counter analysis. I was impressed with his confidence and his expertise and decided to retain his services. He worked on my file around the clock to ensure meeting the deadline. At the end, Sam was able to reduce the tax bill and I was able to pay it with no hesitation. While Sam was working on the file, he was in a full control with the situation by communicating with the auditor on timely and professional manners. I never felt that I was left in the dark as Sam was always providing me with an update. I do recommend to hire Sam for any dispute with the CRA. Thanks
Had a consultation with Sam about a tax situation and very glad I got professional advice on how to proceed.
Sam helped me during a tax audit with the CRA. His performance was beyond expectation and I am very satisfied with the end results. Sam has demonstrated a high business and ethics standards and more importantly, he met all his promises. Well deserved excellent rating.
Response from the owner:Thank you Mr. Zahir for your positive feedback.
Very glad I contacted Sam and his team for help with my tax situation. I had worked with other accountants in the past but none of them were as knowledgeable and easy to work with as the Faris CPA team. They were able to help me resolve my situation and better prepare for the future.

Update - it’s been a few years now and can confirm that working with Sam as my tax consultant was an excellent choice and highly recommend him!
Save your time and money and hire Sam Faris for any problem with the CRA. He is the man to fight the CRA and get you the best results. His firm a top consulting firm I have ever dealt with. He is honest, trustworthy and very professional on both personal and business levels. He won my case against the CRA and the audit went through very smoothly because of his top notch service and expertise. I wish I met Sam before. I paid other professionals but they were disappointing and did not deliver what Sam delivered.
Many thanks Sam and I will definitely refer my clients and family to him.
Response from the owner:Thank you for the five stars Google review and your kind words. We strive to provide the best customer service and to ensure that our clients feel that they are in a safe hands while we are working on their files. We understand that CRA audits are not a pleasant experience to have and we do our best to provide strong arguments to dispute CRA’s decisions and protect our clients’ best interests. Thanks you again and we will remain at your disposal if you need our service in the future.
I was referred to Sam Faris by a tax lawyer to handle my a complicated tax audit by the CRA and to refile all my outstanding corporate and personal tax returns. He was highly recommended by the tax lawyer and by other professional. The minute I hired Sam to sort out the big mess that I had with the CRA, I felt I am safe and in a good hands. He and his team were responsive to my questions and my concerns. Once he completed his work, he insisted to meet in person with the auditor and the team leader. His work quality was second to none. He backed up all accounts prepared a perfect reconciliation. On that basis, he presented his work confidentially and was able to convince the CRA team with his position and his calculations. I must admit that Sam Faris is the best tax consultant and he is a life saver. As a side note, his fee is very reasonable considering to other professionals and more importantly the work quality and the results that he achieved are unbeatable.
Response from the owner:Many thanks Moss for the positive review.
I was referred to Mr. faris by a friend of mine who happened to be his client for more than 10 years. I was struggling with the CRA reading HST and income tax audit. CRA claimed that I owe significant amount of HST and income tax. Mr. Faris was able to perform a detailed analysis which was backed up with previous court cases. As a result of his sophisticated work, he was able to convince CRA that the property was not subject to HST and income tax and the case was closed with zero hst owing. Thank you Mr. Faris for all your hard work.
Sam and his team are an amazing tax consulting firm. They know how the CRA operates and are able to get results based on your actual numbers, not the inflated CRA ones. More importantly, they are super professional and more cost-effective than I would've thought. The Faris team really are life-savers!
Response from the owner:Dear Aymann Your feedback is much appreciated. We have been in business many years now. We have dealt with countless and different types of CRA audits. We noticed that the CRA always attempt to assess on inflated numbers. We have been successful to reduce the CRA numbers and to prove to the CRA their numbers are inflated. As result, CRA would accept our numbers as our work is perfectly reconciled and backed up with the appropriate documents.