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GST/HST Notice of Objection (Canada)
A GST/HST assessment hits Canadian businesses where it hurts: denied input tax credits, reclassified supplies, the wrong provincial rate — and unlike income tax, the Canada Revenue Agency can collect the assessed amount while you dispute it. Our Canadian template produces a formal notice of objection under section 301 of the Excise Tax Act: filed with the Chief of Appeals within the hard 90-day window, with an issue-aware grounds framework, a supplier-by-supplier ITC documentation matrix, the specified-person compliance larger registrants must meet, a written payment posture, and the section 306 Tax Court of Canada route mapped.
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Notice of Objection — GST/HST
Objection Filed Under Section 301 Of The Excise Tax Act · June 8, 2026
Maple Ridge Cabinetry Inc.
1138 Industrial Way, Kamloops BC V2C 6V5
+1 (250) 555-0173
priya@mapleridgecabinetry.ca
June 8, 2026
Chief of Appeals — Canada Revenue Agency
Appeals Intake Centre
1050 Notre Dame Avenue
Sudbury ON P3A 5C1
1050 Notre Dame Avenue
Sudbury ON P3A 5C1
NOTICE OF OBJECTION — GST/HST
Period: Q2 2025 (April 1 – June 30, 2025) · BN: 784512369 RT0001
Dear Chief of Appeals,
The registrant objects to the GST/HST assessment for the reporting period Q2 2025 (April 1 – June 30, 2025), notice of which is dated April 28, 2026. This letter is a notice of objection filed under section 301 of the Excise Tax Act: it sets out the reasons for the objection and all relevant facts. The principal matter in issue is denied or reduced input tax credits, and the amount in dispute is approximately 14,720.00 CAD.
The registrant objects to the GST/HST assessment for the reporting period Q2 2025 (April 1 – June 30, 2025), notice of which is dated April 28, 2026. This letter is a notice of objection filed under section 301 of the Excise Tax Act: it sets out the reasons for the objection and all relevant facts. The principal matter in issue is denied or reduced input tax credits, and the amount in dispute is approximately 14,720.00 CAD.
1.
REGISTRANT DETAILS
Registrant: Maple Ridge Cabinetry Inc.
Business Number / GST-HST account: 784512369 RT0001
Contact for this objection: Priya N. Sharma, President
Address: 1138 Industrial Way, Kamloops BC V2C 6V5
Telephone: +1 (250) 555-0173
Email: priya@mapleridgecabinetry.ca
Business Number / GST-HST account: 784512369 RT0001
Contact for this objection: Priya N. Sharma, President
Address: 1138 Industrial Way, Kamloops BC V2C 6V5
Telephone: +1 (250) 555-0173
Email: priya@mapleridgecabinetry.ca
2.
ASSESSMENT UNDER OBJECTION
Reporting period: Q2 2025 (April 1 – June 30, 2025)
Date of the notice of assessment: April 28, 2026
Reference number: GST-2026-1147209
Principal issue: Denied or reduced input tax credits
Amount in dispute (approximate): 14,720.00 CAD
Date of the notice of assessment: April 28, 2026
Reference number: GST-2026-1147209
Principal issue: Denied or reduced input tax credits
Amount in dispute (approximate): 14,720.00 CAD
3.
FILING WITHIN TIME
This notice of objection is filed within 90 days after the day notice of the assessment was sent, as subsection 301(1.1) of the Excise Tax Act requires. A written objection delivered to the Chief of Appeals is a valid filing — Form GST159 is an alternative, not a requirement.
4.
OUTCOME SOUGHT
The registrant respectfully asks the Minister to allow this objection and reassess to reduce the net tax, penalties and interest assessed. On receipt of this objection the Minister must, with all due dispatch, reconsider the assessment and vacate or confirm it or make a reassessment (subsection 301(3) of the Excise Tax Act), and notify the registrant of the decision in writing.
5.
GROUNDS OF OBJECTION
The assessment denies input tax credits on lumber, hardware and subcontracted finishing acquired for our cabinet-making business. Every purchase was for commercial activities, the suppliers are registered, and the invoices carry the registration numbers and tax amounts the regulations require. The credits should be allowed in full.
6.
DETAILED GROUNDS OF OBJECTION
The assessment denies input tax credits to which the registrant is entitled. Under section 169 of the Excise Tax Act, a registrant may claim an ITC for GST/HST paid or payable on property and services acquired for consumption, use or supply in the course of commercial activities. The documentation tiers in the Input Tax Credit Information (GST/HST) Regulations are met for each claim scheduled below — supplier identity for supplies under $100, the supplier’s registration number and the tax amount from $100, and the recipient, terms and description from $500 — and where a record was incomplete, the corrected or supplementary documentation is identified. The inputs were acquired for commercial activities, the tax was actually paid or payable, and each credit should be allowed.
The correct position: Net tax for the period should be reduced by 14,720.00 CAD of input tax credits on commercial inputs, restoring the amounts claimed on the original return.
Grounds in detail: The company manufactures and installs custom cabinetry. The denied credits relate to lumber and sheet goods, hardware, and subcontracted spray-finishing — all consumed in taxable construction supplies invoiced to customers with GST/HST collected and remitted. The auditor treated several supplier invoices as deficient; the corrected invoices and supplier registration confirmations are scheduled below.
The registrant responded to the audit or proposal letter before the assessment was issued, and those representations are maintained and incorporated in this objection.
The correct position: Net tax for the period should be reduced by 14,720.00 CAD of input tax credits on commercial inputs, restoring the amounts claimed on the original return.
Grounds in detail: The company manufactures and installs custom cabinetry. The denied credits relate to lumber and sheet goods, hardware, and subcontracted spray-finishing — all consumed in taxable construction supplies invoiced to customers with GST/HST collected and remitted. The auditor treated several supplier invoices as deficient; the corrected invoices and supplier registration confirmations are scheduled below.
The registrant responded to the audit or proposal letter before the assessment was issued, and those representations are maintained and incorporated in this objection.
7.
INPUT TAX CREDIT DOCUMENTATION
Each input tax credit in issue is supported by documentation meeting the tiers of the Input Tax Credit Information (GST/HST) Regulations (supplier identity under $100; plus the supplier’s GST/HST registration number and tax amount from $100; plus the recipient, terms and description from $500):
1. Interior Forest Products Ltd. — invoice dated April 14, 2025 — ITC 6,240.00 CAD — Documentation held: Invoice with supplier BN and HST shown; registry confirmation printout
2. Coastal Hardware Distributors Inc. — invoice dated May 6, 2025 — ITC 4,980.00 CAD — Documentation held: Corrected invoice issued May 2026 showing registration number and tax
3. Thompson Valley Finishing Co. — invoice dated June 21, 2025 — ITC 3,500.00 CAD — Documentation held: Subcontract, progress invoices and payment records
Each credit is claimed within the statutory window — generally four years under subsection 225(4) of the Excise Tax Act (two years for specified persons and listed financial institutions).
Remediation of incomplete records: Coastal Hardware reissued its May 2025 invoice in corrected form showing its GST/HST registration number and the tax charged; the original and corrected invoices are both enclosed.
1. Interior Forest Products Ltd. — invoice dated April 14, 2025 — ITC 6,240.00 CAD — Documentation held: Invoice with supplier BN and HST shown; registry confirmation printout
2. Coastal Hardware Distributors Inc. — invoice dated May 6, 2025 — ITC 4,980.00 CAD — Documentation held: Corrected invoice issued May 2026 showing registration number and tax
3. Thompson Valley Finishing Co. — invoice dated June 21, 2025 — ITC 3,500.00 CAD — Documentation held: Subcontract, progress invoices and payment records
Each credit is claimed within the statutory window — generally four years under subsection 225(4) of the Excise Tax Act (two years for specified persons and listed financial institutions).
Remediation of incomplete records: Coastal Hardware reissued its May 2025 invoice in corrected form showing its GST/HST registration number and the tax charged; the original and corrected invoices are both enclosed.
8.
COLLECTIONS AND PAYMENT POSTURE
The registrant is aware that, unlike an income tax debt, a GST/HST assessment carries no collection hold during an objection: under subsection 315(2) of the Excise Tax Act assessed amounts are payable forthwith, and filing this objection does not stop collection, set-off of refunds and credits, or interest accruing at the prescribed arrears rate — currently 7% per annum, compounded daily (April–June 2026 quarter).
The registrant is paying the assessed amount under protest and without admission, to stop interest accruing and remove any collection exposure while the objection is decided. If the objection succeeds, the overpayment is to be refunded with interest.
Payment particulars: A payment of 14,720.00 CAD was made on May 15, 2026 and is to be applied to the assessed period pending the outcome of this objection.
A parallel request under the CRA’s taxpayer relief provisions is being made for cancellation of penalties and interest that should not stand whatever the outcome of this objection.
The registrant is paying the assessed amount under protest and without admission, to stop interest accruing and remove any collection exposure while the objection is decided. If the objection succeeds, the overpayment is to be refunded with interest.
Payment particulars: A payment of 14,720.00 CAD was made on May 15, 2026 and is to be applied to the assessed period pending the outcome of this objection.
A parallel request under the CRA’s taxpayer relief provisions is being made for cancellation of penalties and interest that should not stand whatever the outcome of this objection.
9.
NEXT STEPS — TAX COURT OF CANADA
If the assessment is confirmed in whole or in part, the registrant intends to appeal to the Tax Court of Canada under section 306 of the Excise Tax Act, electing the informal procedure (available for GST/HST appeals where the amount in dispute is $50,000 or less, or by election to limit the appeal to that amount). The appeal will be instituted within 90 days after the decision on this objection is sent — and the registrant notes that if no decision issues within 180 days of this filing, an appeal may be taken directly to the Court.
10.
ACKNOWLEDGEMENT AND DECISION
Please acknowledge receipt of this objection in writing, confirm the date it was received and provide the case number assigned to it. The registrant asks that the objection be decided with all due dispatch as subsection 301(3) of the Excise Tax Act requires, and that the Appeals Officer make contact before deciding it if any further information or document would assist. All rights of appeal to the Tax Court of Canada under section 306 are reserved.
YOURS TRULY,
Priya N. Sharma
Registrant
Date: ____________________
REGISTRANT
Priya N. Sharma
President
Maple Ridge Cabinetry Inc.
Date: ____________________
Available as a print-ready PDF or an editable Microsoft Word (.docx) file.
What Is a GST/HST Notice of Objection?
It is the formal dispute mechanism for GST/HST assessments in Canada. A registrant assessed for net tax, penalties or interest may file a notice of objection with the <strong>Canada Revenue Agency</strong> within <strong>90 days</strong> after the notice of assessment is sent (Excise Tax Act, s.301(1.1)) — and unlike individual income tax, there is no one-year alternative. A signed letter to the Chief of Appeals stating the facts and reasons is a complete objection; Form GST159 and "Register my formal dispute" in My Business Account are alternatives. In Quebec, Revenu Québec administers GST/HST and takes the objection instead.
The single most important difference from an income tax dispute is collection. There is no equivalent of the income tax collection hold for GST/HST: under the Excise Tax Act, assessed amounts are payable forthwith, and the CRA may garnish, set off refunds or otherwise collect <strong>even while the objection is outstanding</strong>. A Canadian business that files an objection and assumes the debt is paused can be blindsided by a requirement to pay on its bank. The objection therefore needs a payment posture in writing — pay under protest, arrange instalments, or ask collections to stay enforcement — and this template states it expressly.
Larger registrants carry an extra burden. A "specified person" — broadly, a business over $6 million in taxable supplies in the current and previous fiscal year, or a listed financial institution — must describe each issue, quantify the relief sought per issue as a change in an amount, and give the facts and reasons for each (s.301(1.2)). Issues not raised that way are generally barred from the Tax Court of Canada later (s.306.1). Most small businesses are not specified persons, but the template can draft to the higher standard on request — useful insurance when the threshold is close.
What's Covered in This Template
The letter follows the structure a CRA Appeals Officer works through for GST/HST — registrant, period, time limit, outcome, grounds, documentation — and adapts to the issue in dispute.
Issue-Aware Grounds
Choose denied input tax credits, supply classification, place of supply, the new housing rebate or s.280 penalties — the Expert grounds clause writes the matching Excise Tax Act framework.
Hard 90-Day Window
The letter confirms filing within 90 days of the notice (s.301(1.1)) — and where the window has passed, adds the s.303 extension application with the statutory conditions argued.
ITC Documentation Matrix
A supplier-by-supplier table of the denied credits: invoice dates, amounts, and the documentation held against the $100 / $500 regulation tiers — with corrected invoices noted.
Four-Year Claim Window
Positions each credit inside the s.225(4) window — generally four years for most Canadian registrants, two for specified persons and listed financial institutions.
No-Collection-Hold Warning
States the rule most registrants learn too late: GST/HST amounts are payable forthwith and objection does not pause collection — then records your chosen payment posture.
Payment Posture Options
Pay under protest (stops interest, refunded if you win), request a payment arrangement, confirm payment in full, or ask collections to hold enforcement — each in officer-ready wording.
Specified-Person Compliance
For businesses over the $6 million threshold: each issue described, relief quantified per issue, facts and reasons given — preserving every issue for the Tax Court (s.306.1).
Relief Cross-Reference
Notes a parallel penalty-and-interest relief request on the file, so amounts that should not stand are attacked on both tracks at once.
Tax Court Route — s.306
Records the appeal path: 90 days from the decision, the $50,000 informal procedure for GST/HST disputes, and the right to go straight to the Court after 180 days of CRA silence.
How to Create a GST/HST Objection
Five steps from assessment to filed objection.
- 1
Find the Notice
You need the reporting period, the date on the notice of assessment and the reference number — plus your Business Number and RT account. The 90-day clock runs from the notice date.
- 2
Name the Issue
Denied ITCs, classification, place of supply, the housing rebate or penalties — pick the dominant issue and state in two or three sentences why the assessment is wrong.
- 3
Build the Matrix (Expert)
For ITC disputes, list each supplier, invoice and amount with the documentation held. A corrected or reissued invoice cures most documentation denials.
- 4
Fix the Payment Posture (Expert)
Decide before the CRA does: pay under protest, arrange instalments or request a hold — and put it in writing so the collections file shows it.
- 5
File and Keep the Record
Mail the letter to the Chief of Appeals at the Appeals Intake Centre, or register the dispute in My Business Account and upload it. In Quebec, file with Revenu Québec instead. Keep a dated copy.
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Legal Considerations
GST/HST disputes run on the Excise Tax Act's own clock and rules — several of them harsher than the income tax equivalents Canadians know better.
This template provides general information for Canadian registrants and is not tax or legal advice. For large assessments, specified-person files, or disputes entangled with director liability or trust-fund amounts, get advice from a Canadian GST/HST lawyer or CPA before filing.
Reviewed for Canadian tax law
The Right to Object — s.301 of the Excise Tax Act
A person assessed under Part IX may file a notice of objection within 90 days after the notice of assessment is sent, setting out the reasons and the relevant facts (s.301(1.1)). The Minister must then reconsider the assessment with all due dispatch and vacate or confirm it or reassess (s.301(3)). The objection goes to the Chief of Appeals — a letter is a valid filing, Form GST159 an alternative — and in Quebec the objection is filed with Revenu Québec, which administers GST/HST there.
No Collection Hold — the Rule That Surprises
For individual income tax, serving an objection restricts CRA collection. For GST/HST it does not: assessed net tax, penalties and interest are payable forthwith under the Excise Tax Act, and the CRA may issue a requirement to pay, set off refunds and credits, or certify the debt while the objection runs. Interest accrues throughout at the prescribed rate plus 4% — 7% per annum for the April–June 2026 quarter, compounded daily. The practical answers are payment under protest (refunded with interest on success) or a payment arrangement — see our CRA payment arrangement request template.
Input Tax Credits — Documentation Wins and Loses Them
ITCs flow from s.169 of the Excise Tax Act for tax paid on inputs to commercial activities, but the Input Tax Credit Information (GST/HST) Regulations set documentation tiers — supplier identity below $100; plus the supplier's GST/HST registration number and the tax amount from $100; plus the recipient, terms and a description from $500. Most denials are documentation denials, and a corrected or reissued invoice cures the defect. The claim window is generally four years (s.225(4)); about two for specified persons and listed financial institutions.
Specified Persons — the $6 Million Standard
A registrant whose taxable supplies exceeded $6 million in both the current and previous fiscal year — or any listed financial institution — must file to the higher s.301(1.2) standard: each issue reasonably described, the relief per issue quantified as a change in an amount, and facts and reasons for each. The CRA may request missing particulars with 60 days to comply, and issues not properly raised are generally barred on appeal (s.306.1). The template writes that compliance in, and can apply it protectively when the threshold is close.
After the Objection — s.306 and the 180-Day Lever
If the Minister confirms or reassesses, the registrant may appeal to the Tax Court of Canada within 90 days (s.306). And if the CRA issues no decision within 180 days of filing, the registrant may appeal directly — a lever worth knowing when interest is compounding on a collectible debt. The informal procedure covers GST/HST disputes of $50,000 or less, or larger files that elect to cap the amount. For the income tax side of the same audit, use our CRA notice of objection template; for the penalties and interest, our CRA taxpayer relief request.
Frequently Asked Questions
Dispute the Assessment — and Manage the Debt While You Do
Create your GST/HST notice of objection in minutes: issue-aware grounds, the ITC documentation matrix, specified-person compliance and a written payment posture, in formal Canadian letter format. Download the PDF free, or unlock Expert for the matrix, collections and Tax Court sections.
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