The full list of CRA tax centres can be found at cra-arc.gc.ca/cntct/tso-bsf-eng.html
The Notice of Objection is form T400A.
Don’t leave anything out.
It can be hard to add additional arguments if it’s not in the notice of objection.
–Bruce Ball, CA, national tax partner with BDO Canada LLP
Wait. It can take six to 12 months for a CRA review.
You lose | You win! |
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The appeals officer disagrees and confirms the original assessment. Your client has 90 days to appeal to the Tax Court of Canada. Keep going. |
The appeals officer agrees, adjusts the tax return, and issues a notice of reassessment. You’re done! |
Do a cost analysis.
If your client has a solid case, compare total funds recoverable with an estimate of fees. Cases that go to court cost more. Factor that in.
“If it is a question of whether the matter is contrary to CRA policies and practices, then it is less likely to be settled because questions of law may impact many more taxpayers,” says Paul Lynch, tax partner with KPMG LLP in Ottawa.
CRA’s stake rises as the dispute works through the process. So, although it has resources to ght, CRA is motivated to resolve matters early.
If it makes it to court, there’s the risk CRA could lose, and that would set a precedent. So they’ll often try to settle, say experts, which is to a taxpayer’s advantage if the amounts are small enough—say, $10,000. After all, getting rid of a $50,000 tax bill could cost $150,000 if it goes to court.
Advantage! You or your client can appear before the judge. You don’t need a lawyer!
For larger sums, you’re stuck with the general procedure.You need a lawyer.
OPTION Or, get the yearly total under $12,000 by paying tax on the difference and keep the discussions informal. This formula can be applied to multiple tax years.
Our sources: Bruce Ball, national tax partner, BDO Canada LLP, Toronto; Gerald Grenon, partner, KPMG Law LLP, Calgary; Paul Lynch, CA, KPMG, Ottawa, Ont.; James Rhodes, TaxationLawyers, Kitchener, Ont.
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