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If the Canada Revenue Agency (CRA) has not decided an income-tax objection, you may be able to appeal to the Tax Court of Canada after 90 days have passed since you filed the objection. If the CRA has sent a decision, the CRA guide says the Court must receive your notice of appeal within 90 days of the date the decision was sent. Those periods apply to the Canadian income-tax process described here, not automatically to every country, tax authority or tax type. Confirm the authority that issued the reassessment and the governing statute before relying on a deadline.
Keep proof of when your objection was filed, preserve the reassessment and correspondence, and contact the CRA through the number or contact channel on the notice to confirm receipt and ask for a status explanation. A status enquiry does not replace a formal appeal and does not extend a statutory deadline.
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Start by identifying the exact tax process
“Reassessment objection” is not a universal procedure. The deadline and appeal route depend on the country, authority, tax type and taxpayer category. Before counting days, write down:
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- the country and tax authority named on the reassessment;
- whether the dispute concerns income tax, GST/HST or another tax;
- whether you are an individual, corporation or another taxpayer category;
- the date on the notice of reassessment or redetermination;
- the date your objection was filed and how you can prove delivery; and
- whether the authority has sent a decision on the objection.
The rules below use the CRA’s Canadian income-tax guidance. If your notice comes from another authority, or concerns a different Canadian tax, use that authority’s current instructions rather than importing the 90-day income-tax rule.
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What the CRA says when an income-tax objection is still undecided
In Resolving your dispute: Objection rights under the Income Tax Act, the CRA states: “You can also appeal to the Court if we do not give you a decision on your objection within 90 days of the day you filed it.” In practical terms, an unanswered objection does not necessarily leave you without a next step. Once the applicable 90-day period has elapsed, a taxpayer in the Canadian income-tax process can consider an appeal to the Tax Court of Canada.
The same guide describes a different 90-day clock when the CRA has decided the objection. The notice of appeal must reach the Court within 90 days of the date the CRA sent its decision. The trigger is therefore different in the two situations: the filing date of the objection when there is no decision, and the date the decision was sent when there is one.
| Situation | Canadian income-tax timing described by CRA | What to preserve |
|---|---|---|
| No objection decision | Tax Court appeal may be available after 90 days from the day the objection was filed. | Objection filing date, proof of receipt and all CRA correspondence. |
| CRA sends an objection decision | Notice of appeal must reach the Court within 90 days of the date the decision was sent. | The decision, the date it was sent and evidence of when the Court received the appeal. |
These are procedural thresholds, not promises that the CRA will finish an objection within a particular number of days. The reviewed CRA material does not provide a typical processing-time average, so do not plan around an assumed wait-time statistic.
Check that the objection was actually filed
Before treating the matter as an unanswered objection, verify that the CRA received a valid filing. An apparent silence can result from a submission that went to the wrong office, lacked required information or cannot be matched to the taxpayer’s account.
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- Locate the filing record. Save the copy of the objection, the transmission confirmation, delivery record, account message or other proof showing when the CRA received it.
- Match it to the reassessment. Confirm that the objection identifies the correct tax year, notice and taxpayer account. Keep the notice of reassessment or redetermination with the objection.
- Build a dated chronology. List the reassessment date, objection date, delivery confirmation, follow-up contacts and every CRA letter or electronic message.
- Check for a decision already sent. Search your paper and electronic records, including messages delivered through the CRA’s available account channels. A decision date can start the separate 90-day appeal period.
- Recalculate the waiting period. Count 90 days from the date the objection was filed, using the date supported by your receipt evidence. If the applicable tax statute or current Court rules use a different method, follow those rules.
If you cannot prove the filing date, contact the CRA promptly and ask what date appears on its record. Do not assume that a telephone conversation changes the statutory filing date.
Contact the CRA without losing sight of the deadline
The CRA recommends contacting the number on the notice or its listed contact channels before sending an objection or appealing. Use that contact step to resolve administrative uncertainty, not as a substitute for the formal process.
Questions to ask
- Has the CRA received and registered my objection?
- What filing date appears on the CRA record?
- Has a decision been issued, and if so, on what date was it sent?
- Is any information missing that prevents the objection from being reviewed?
- Where should further documents be sent, and how will delivery be acknowledged?
Record the date, channel, representative’s name or identification information if provided, and a concise summary of the answer. Ask for written confirmation when the issue concerns receipt, a decision date or missing documents. Keep copies of anything you send after the original objection.
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1Scan for outdated or missing drivers - takes under a minute2Repair Windows errors before they cause bigger problems3Fix the driver behind crashes, sound loss and screen glitchesA status request does not pause or extend the time to appeal. If the 90-day threshold is approaching or has passed, continue preparing for the formal appeal while you seek clarification.
Preparing a Tax Court appeal after no decision
If the Canadian income-tax objection has remained undecided for 90 days, decide whether an appeal is appropriate rather than waiting indefinitely. An appeal is a separate legal proceeding; it is not an automatic escalation of a telephone enquiry.
- Confirm the governing route. Verify that the matter is an income-tax objection covered by the CRA guide and that no special rule changes the period. GST/HST and other taxes can use different procedures.
- Confirm the dates. Use your evidence of the objection’s filing date and document when the 90-day period expires. If the CRA sent a decision in the meantime, switch to the decision-based 90-day period.
- Assemble the record. Gather the reassessment, objection, schedules, supporting documents, CRA letters, account messages, delivery proof and your chronology. Organize them so the Court and the CRA can identify each tax year and issue.
- Read the Tax Court’s current instructions. Obtain the current notice-of-appeal form, filing method, service requirements and any fee or formatting rules directly from the Tax Court of Canada. Court procedures can change, and the CRA guide’s 90-day statement does not replace the Court’s current directions.
- File within the applicable period. Ensure the notice of appeal reaches the Court within the period required for your circumstances. Keep the filed copy and the Court’s confirmation of receipt.
- Continue responding to official requests. After filing, follow the Court’s directions and any communications from the CRA. Missing a later procedural deadline can create a new problem even when the appeal itself was timely.
For a substantial amount, multiple tax years, technical valuation issues or a business dispute, obtain advice from a qualified Canadian tax-dispute professional before filing. A professional can assess jurisdiction, pleadings, evidence and settlement options, but you remain responsible for verifying the provider and every deadline.
If the CRA sends a decision while you are waiting
Read the decision immediately and record the date the CRA sent it. Under the CRA income-tax guide, the Tax Court must receive the notice of appeal within 90 days of that sent date. Do not continue counting from the original objection filing date once a decision has been issued; the decision-based clock governs the appeal described by the guide.
Compare the decision with the reassessment and your objection. Identify which issues were accepted, denied or left unresolved, and keep the complete decision rather than only the first page. If the decision arrives close to the end of a deadline, seek advice promptly and use the Court’s current filing instructions.
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Do not confuse the objection deadline with the appeal deadline
The time allowed to file an initial objection is a separate clock from the period for appealing an unanswered or decided objection. CRA’s income-tax objection decision tree describes different initial deadlines by taxpayer category.
| Taxpayer category | Initial objection deadline described by CRA |
|---|---|
| Individuals | Generally the later of one year after the return-filing deadline or 90 days after the notice of reassessment or redetermination. |
| Corporations | Generally 90 days from the date of the notice. |
“Generally” matters: the applicable notice, tax year and taxpayer status can change the result. A person who missed the initial objection deadline cannot simply use the 90-day no-decision appeal route as a cure. First address whether a late-objection application is available.
What a late-objection extension is—and is not
Section 166.1 of Canada’s Income Tax Act allows an application to the Minister to extend the time for filing an objection, with reasons for the delay stated in the application. This remedy concerns a missed initial objection deadline. It is different from an objection that was filed on time but has not yet received a decision.
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GST/HST and other taxes can follow different rules
Do not apply the income-tax 90-day waiting period to GST/HST merely because both matters involve a reassessment. The CRA’s Objections and Appeals – GST/HST Memorandum 31-0 describes a separate no-decision appeal trigger; the surfaced guidance identifies 180 days for the GST/HST route. Confirm the tax type on the notice and read the current memorandum or statute that governs it.
The same caution applies to payroll, excise, customs, provincial and territorial taxes, and reassessments issued outside Canada. The authority, legislation, taxpayer category and notice wording determine the remedy. If any of those are unclear, obtain clarification before allowing a deadline to pass.
Payment and collection are separate questions
The sources reviewed do not establish that filing an objection automatically suspends payment or collection for every taxpayer and tax type. Do not assume that an unanswered objection stops interest, payment obligations, collection contact or enforcement.
Read the reassessment and any collection correspondence for the amount due and its payment date. If a payment deadline or collection action is imminent, contact the CRA using the details on the notice and obtain qualified advice about relief, security, payment arrangements or other options that may apply to your facts. Keep evidence of every request and response. A request for time to pay does not replace an objection or appeal.
Documents to keep in one case file
- the original notice of reassessment or redetermination and any later reassessments;
- the complete objection and every schedule or attachment filed with it;
- proof of delivery, electronic transmission or CRA receipt;
- the CRA decision, if one is issued, including the date it was sent;
- letters, account messages, telephone notes and document requests;
- returns, slips, invoices, contracts, calculations and other evidence supporting the disputed items;
- a chronology showing every filing, contact and deadline; and
- copies of any Tax Court filing and confirmation of receipt.
Use consistent file names and keep an untouched copy of originals. The goal is to prove both the substantive tax position and the procedural dates.
Common mistakes that create avoidable risk
- Waiting for a personal reply before acting. The CRA’s 90-day income-tax route is tied to the filing date, not to the number of follow-up calls you make.
- Counting from the wrong event. A no-decision appeal uses the objection filing date; an appeal after a decision uses the date the decision was sent.
- Assuming every tax uses 90 days. GST/HST guidance identifies a different 180-day no-decision trigger.
- Confusing a late objection with an unanswered objection. Section 166.1 addresses an application to extend a missed objection deadline; it is not the same remedy.
- Relying on an unrecorded conversation. Preserve written proof of receipt, dates and instructions.
- Assuming collection is frozen. Verify payment and collection consequences for the specific notice.
- Using outdated forms or rules. Check current CRA, Tax Court and statutory instructions before filing.
A practical decision path
- Different authority or tax type? Stop and obtain that authority’s procedure before using any Canadian income-tax deadline.
- Income-tax objection filed? If not, determine the initial objection deadline for your taxpayer category and notice.
- Proof of filing available? If not, contact the CRA immediately and reconstruct delivery evidence.
- Decision sent? If yes, calculate the 90-day period from the date it was sent and follow Tax Court instructions.
- No decision after 90 days? For the Canadian income-tax process, consider a Tax Court appeal and verify current law and Court requirements.
- Payment or collection imminent? Address that issue separately; do not assume the objection or appeal pauses it.
The essential record is simple: identify the correct tax regime, prove when the objection was filed, distinguish no decision from a decision already sent, and protect the applicable appeal deadline.
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