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CRA Notice of Objection — Income Tax (Canada)
If you disagree with a Notice of Assessment or Reassessment from the Canada Revenue Agency — denied expenses, income added that is not yours, a 50% gross negligence penalty or a benefit clawback — you have a statutory right to object. Our Canadian template produces a formal notice of objection under subsection 165(1) of the Income Tax Act, served on the Chief of Appeals with issue-aware grounds, the onus framework from Hickman Motors, a numbered evidence schedule, the s.166.1 late-objection rescue and the s.225.1 collection hold positioning — with the Tax Court of Canada route mapped if Appeals confirms the assessment.
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Notice of Objection — Income Tax
Objection Served Under Subsection 165(1) Of The Income Tax Act · June 8, 2026
Daniel R. Mercer
2415 Brentwood Drive NW, Calgary AB T2L 1L3
+1 (403) 555-0184
daniel.mercer@email.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 — INCOME TAX
Taxation year: 2024 · Ref: NR-2026-0481537
Dear Chief of Appeals,
I object to the Notice of Reassessment for the 2024 taxation year, dated March 12, 2026. This letter is a notice of objection served under subsection 165(1) of the Income Tax Act: it is in writing and, as that subsection requires, it sets out the reasons for the objection and all relevant facts. The amount in dispute is approximately 9,840.00 CAD.
I object to the Notice of Reassessment for the 2024 taxation year, dated March 12, 2026. This letter is a notice of objection served under subsection 165(1) of the Income Tax Act: it is in writing and, as that subsection requires, it sets out the reasons for the objection and all relevant facts. The amount in dispute is approximately 9,840.00 CAD.
1.
TAXPAYER DETAILS
Full name: Daniel R. Mercer
SIN / Business Number: 123-456-789
Address: 2415 Brentwood Drive NW, Calgary AB T2L 1L3
Telephone: +1 (403) 555-0184
Email: daniel.mercer@email.ca
Taxpayer type: Individual
SIN / Business Number: 123-456-789
Address: 2415 Brentwood Drive NW, Calgary AB T2L 1L3
Telephone: +1 (403) 555-0184
Email: daniel.mercer@email.ca
Taxpayer type: Individual
2.
ASSESSMENT UNDER OBJECTION
Notice objected to: Notice of Reassessment
Taxation year: 2024
Date of the notice: March 12, 2026
Reference number: NR-2026-0481537
Amount in dispute (approximate): 9,840.00 CAD
Taxation year: 2024
Date of the notice: March 12, 2026
Reference number: NR-2026-0481537
Amount in dispute (approximate): 9,840.00 CAD
3.
SERVICE WITHIN TIME
As an individual (other than a trust) I may serve this notice of objection on or before the later of the day that is one year after my filing-due date for the taxation year and the day that is 90 days after the day of sending of the notice (paragraph 165(1)(a) of the Income Tax Act). This objection is accordingly served in time, and a written objection delivered to the Chief of Appeals is a valid mode of service — no prescribed form is required.
4.
OUTCOME SOUGHT
I respectfully ask the Minister to allow this objection and reassess to reduce the amounts assessed. I understand that on receipt of this objection the Minister must, with all due dispatch, reconsider the assessment and vacate, confirm or vary it or reassess (subsection 165(3) of the Income Tax Act), and must notify me of the decision in writing.
5.
GROUNDS OF OBJECTION
The reassessment denies my employment expenses for 2024 in full. My employer required me to use my own vehicle and pay my own travel costs, certified that requirement on Form T2200, and I kept a mileage log and receipts. The expenses were genuinely incurred to earn my employment income and should be allowed as claimed.
6.
DETAILED GROUNDS OF OBJECTION
The assessment denies deductions or credits to which I am entitled. An outlay is deductible to the extent it was made or incurred for the purpose of gaining or producing income and is reasonable in the circumstances, and the corresponding credits (including employment-expense, medical-expense and donation claims) are conferred by the Income Tax Act on the facts as they actually occurred. The records scheduled with this objection show that each amount claimed was genuinely incurred, was properly documented and meets the statutory conditions. I ask the Minister to review each denied amount against that evidence and to allow it.
The correct position: My 2024 taxable income should be reduced by allowable employment expenses of 9,840.00 CAD, comprising motor vehicle expenses for 18,300 employment kilometres and required out-of-town travel costs, as certified by my employer on Form T2200.
Grounds in detail: I work as a field service technician and my written conditions of employment require me to travel daily between client sites using my own vehicle, without reimbursement. My employer signed Form T2200 confirming those conditions. I kept a contemporaneous mileage log distinguishing employment from personal kilometres, and retained fuel, maintenance and insurance records, which support the amounts claimed on Form T777. The reassessment proceeded as if no employment requirement existed; the certificate and log show the opposite.
The correct position: My 2024 taxable income should be reduced by allowable employment expenses of 9,840.00 CAD, comprising motor vehicle expenses for 18,300 employment kilometres and required out-of-town travel costs, as certified by my employer on Form T2200.
Grounds in detail: I work as a field service technician and my written conditions of employment require me to travel daily between client sites using my own vehicle, without reimbursement. My employer signed Form T2200 confirming those conditions. I kept a contemporaneous mileage log distinguishing employment from personal kilometres, and retained fuel, maintenance and insurance records, which support the amounts claimed on Form T777. The reassessment proceeded as if no employment requirement existed; the certificate and log show the opposite.
7.
ONUS AND THE ASSUMPTIONS RELIED ON
An assessment rests on the Minister’s assumptions of fact. In Hickman Motors Ltd v Canada, [1997] 2 SCR 336, the Supreme Court of Canada confirmed that the taxpayer’s initial onus is to "demolish" those assumptions by making out at least a prima facie case, after which the onus shifts to the Crown to prove the assumptions on a balance of probabilities; and where the facts assumed are peculiarly within the CRA’s own knowledge, the ordinary onus is adjusted (Canada v Anchor Pointe Energy Ltd, 2007 FCA 188). Each assumption underlying this assessment is addressed in turn:
1. Assumed: My contract did not require me to work away from the employer’s place of business or pay my own travel costs. — Why it is wrong: The written conditions of employment and Form T2200 certify exactly that requirement. Shown by: Form T2200 (signed February 19, 2025) and employment contract, clause 7.
2. Assumed: The kilometres claimed were personal rather than employment travel. — Why it is wrong: The mileage log records each client site visit by date, destination and distance — 18,300 employment kilometres of 24,100 total. Shown by: Mileage log for January to December 2024.
Information not previously before the CRA: The audit file did not include the February 2025 letter from my employer confirming that no travel allowance or reimbursement was paid in 2024. That letter is item 3 of the evidence schedule.
I was not given a meaningful opportunity to respond before the assessment was issued, so the facts and documents in this objection are before the CRA for the first time — I ask the Appeals Officer to weigh them afresh.
1. Assumed: My contract did not require me to work away from the employer’s place of business or pay my own travel costs. — Why it is wrong: The written conditions of employment and Form T2200 certify exactly that requirement. Shown by: Form T2200 (signed February 19, 2025) and employment contract, clause 7.
2. Assumed: The kilometres claimed were personal rather than employment travel. — Why it is wrong: The mileage log records each client site visit by date, destination and distance — 18,300 employment kilometres of 24,100 total. Shown by: Mileage log for January to December 2024.
Information not previously before the CRA: The audit file did not include the February 2025 letter from my employer confirming that no travel allowance or reimbursement was paid in 2024. That letter is item 3 of the evidence schedule.
I was not given a meaningful opportunity to respond before the assessment was issued, so the facts and documents in this objection are before the CRA for the first time — I ask the Appeals Officer to weigh them afresh.
8.
EVIDENCE SCHEDULE
The following records are relied on in support of each ground. They are the relevant facts required by subsection 165(1) of the Income Tax Act and discharge the taxpayer’s onus described above:
1. Form T2200, Declaration of Conditions of Employment, signed by the employer (dated February 19, 2025) — I was required to travel for work and pay my own motor vehicle expenses
2. Mileage log (January – December 2024) (dated 2024) — 18,300 employment kilometres of 24,100 total kilometres driven
3. Employer letter confirming no allowance or reimbursement was paid (dated February 3, 2025) — the expenses were borne by me personally
4. Fuel, maintenance and insurance receipts bundle (dated 2024) — the actual vehicle costs behind the amounts claimed on Form T777
All listed items are enclosed with this objection.
Notes on the evidence: The vehicle expense claim uses the actual-cost method prorated to the employment-use percentage shown by the log; the supporting calculation is included with the receipts bundle.
1. Form T2200, Declaration of Conditions of Employment, signed by the employer (dated February 19, 2025) — I was required to travel for work and pay my own motor vehicle expenses
2. Mileage log (January – December 2024) (dated 2024) — 18,300 employment kilometres of 24,100 total kilometres driven
3. Employer letter confirming no allowance or reimbursement was paid (dated February 3, 2025) — the expenses were borne by me personally
4. Fuel, maintenance and insurance receipts bundle (dated 2024) — the actual vehicle costs behind the amounts claimed on Form T777
All listed items are enclosed with this objection.
Notes on the evidence: The vehicle expense claim uses the actual-cost method prorated to the employment-use percentage shown by the log; the supporting calculation is included with the receipts bundle.
9.
COLLECTIONS, INTEREST AND NEXT STEPS
I ask the CRA to confirm in writing that, this objection having been served, collection of the amounts in dispute is restricted under section 225.1 of the Income Tax Act until 90 days after the Minister’s decision on the objection is sent. I understand that this restriction does not extend to amounts required to be deducted or withheld at source, that the CRA may still apply refunds and credits against the debt by set-off, and that arrears interest continues to accrue at the prescribed rate plus 4% — 7% per annum for the April–June 2026 quarter — compounded daily on any amount ultimately confirmed. Any undisputed balance is being addressed separately.
If the objection is confirmed in whole or in part, I intend to appeal to the Tax Court of Canada under section 169 of the Income Tax Act within 90 days of the decision, electing the informal procedure (available where the federal tax and penalties in dispute are $25,000 or less for each taxation year, excluding interest, or by election to limit the appeal to that amount).
If the objection is confirmed in whole or in part, I intend to appeal to the Tax Court of Canada under section 169 of the Income Tax Act within 90 days of the decision, electing the informal procedure (available where the federal tax and penalties in dispute are $25,000 or less for each taxation year, excluding interest, or by election to limit the appeal to that amount).
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. I ask that the objection be decided with all due dispatch as subsection 165(3) of the Income Tax Act requires, and that the Appeals Officer contact me before deciding it if any further information or document would assist. I reserve all my rights of appeal to the Tax Court of Canada under section 169.
YOURS TRULY,
Daniel R. Mercer
Taxpayer
Date: ____________________
TAXPAYER
Daniel R. Mercer
Date: ____________________
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What Is a CRA Notice of Objection?
An objection is the formal way to dispute an assessment made by the <strong>Canada Revenue Agency</strong>. It is served under <strong>subsection 165(1) of the Income Tax Act</strong>, must be in writing, and must set out the reasons for the objection and all relevant facts. A signed letter to the Chief of Appeals is a complete objection on its own — Form T400A and the "Register my formal dispute" service in CRA My Account are alternatives, not requirements. The objection moves your file from the auditor or processing centre to the CRA Appeals Division, where an Appeals Officer must reconsider the assessment with all due dispatch and vacate, confirm or vary it.
Timing is generous for individuals but unforgiving for everyone else. An individual (other than a trust) or a graduated rate estate may object up to the <strong>later</strong> of one year after the return's filing-due date and 90 days after the notice was sent; corporations and trusts get 90 days only. Miss the window and section 166.1 allows an extension application within one further year — you must show you could not act or had a bona fide intention to object, that an extension is just and equitable, and that you applied as soon as circumstances permitted. After that year, the assessment generally stands however wrong it is.
A well-built Canadian objection does three jobs at once. It states grounds the Appeals Officer can act on — engaging the actual issue, whether that is a denied deduction, unreported-income dispute, a subsection 163(2) gross negligence penalty (where the burden sits on the Minister, not you) or an audit reassessment. It schedules the evidence, because in Canadian tax disputes the taxpayer must "demolish" the Minister's assumptions with at least a prima facie case (Hickman Motors Ltd v Canada, [1997] 2 SCR 336). And it positions collection: once an individual income tax objection is served, section 225.1 restricts CRA legal collection of the disputed amount until 90 days after the decision — though interest keeps compounding daily and set-off of refunds continues.
What's Covered in This Template
The letter follows the structure a CRA Appeals Officer works through — taxpayer, assessment, time limit, outcome, grounds, evidence — and adapts to the kind of dispute you are raising.
Issue-Aware Grounds
Choose denied expenses or credits, added income, a gross negligence penalty, a benefit clawback or an audit reassessment — the Expert grounds clause writes the matching legal framework around your facts.
90-Day / One-Year Window
The letter positions the s.165(1) deadline for your taxpayer type — individuals and graduated rate estates get the longer of one year from the filing-due date and 90 days from the notice.
Onus & Assumptions Table
A point-by-point rebuttal of the assumptions behind the assessment, built on the Hickman Motors "demolish" framework and Anchor Pointe — what was assumed, why it is wrong, which document shows it.
Evidence Schedule
A numbered, dated list of the records supporting each ground — the relevant facts s.165(1) requires, and the record relied on if the matter reaches the Tax Court of Canada.
Gross Negligence Defence
For s.163(2) penalties — the greater of $100 and 50% of the understated tax — the letter invokes the Venne standard and puts the burden where s.163(3) places it: on the Minister.
Late Objection Rescue
Where the window has passed, the Expert section adds a s.166.1 extension application with the statutory conditions argued, and notes the s.166.2 Tax Court fallback.
Collection Hold Positioning
Asks the CRA to confirm the s.225.1 restriction on collecting the disputed amount — with the honest caveats: source deductions and GST/HST are not covered, set-off continues, and interest accrues at 7% compounded daily.
Tax Court Route
Records whether you will appeal to the Tax Court of Canada under the informal procedure (disputes up to $25,000 per year) or the general procedure, within 90 days of the decision.
Chief of Appeals Format
Letterhead, the Appeals Intake Centre as recipient, subject line, numbered clauses and a single-signer block — ready to mail or to upload through My Account.
How to Create a CRA Notice of Objection
Five steps from Notice of Assessment to served objection.
- 1
Find the Notice
You need the taxation year, the date on the Notice of Assessment or Reassessment and any reference number. Your objection clock runs from that date — individuals also get one year from their filing-due date.
- 2
Say What You Want
Choose the outcome — reassess and reduce, vacate, or reassess on the correct basis — and add two or three sentences on why the assessment is wrong. The detail comes next.
- 3
Build the Grounds (Expert)
Pick the issue — expenses, income, penalty, benefit or audit — and the template writes the statutory framework around your facts, with the correct figure stated.
- 4
Demolish the Assumptions (Expert)
List each assumption the CRA made, why it is wrong and the document that proves it, then schedule the evidence. That is how the onus shifts under Hickman Motors.
- 5
Serve It and Keep the Record
Mail the letter to the Chief of Appeals at the Appeals Intake Centre in Sudbury, or register the dispute in CRA My Account and upload it. Keep a dated copy — the service date fixes whether you are in time.
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Legal Considerations
CRA objections sit inside a structured Canadian review chain with strict, money-protecting time limits.
This template provides general information for Canadian taxpayers and is not tax or legal advice. For complex disputes — large amounts, gross negligence allegations, statute-barred years or transfer-pricing issues — get advice from a Canadian tax lawyer or CPA. The Taxpayers' Ombudsperson handles complaints about how the CRA has treated you; the objection handles whether the assessment is right.
Reviewed for Canadian tax law
The Right to Object — s.165(1)
A taxpayer who objects to an assessment may serve a notice of objection "in writing, setting out the reasons for the objection and all relevant facts" (Income Tax Act, s.165(1)). Individuals (other than trusts) and graduated rate estates may serve it up to the later of one year after the filing-due date and 90 days after the notice was sent; in any other case the limit is 90 days. On receipt, the Minister must reconsider the assessment with all due dispatch and vacate, confirm or vary it or reassess (s.165(3)). The CRA's service standard for low-complexity objections is 180 calendar days.
The Onus — Demolishing the Assumptions
Canadian tax assessments rest on the Minister's assumptions of fact. In Hickman Motors Ltd v Canada, [1997] 2 SCR 336, the Supreme Court of Canada confirmed the taxpayer's initial onus is to "demolish" those assumptions by making out a prima facie case, after which the burden shifts to the Crown; and where the assumed facts are peculiarly within the CRA's knowledge, the ordinary onus adjusts (Canada v Anchor Pointe Energy Ltd, 2007 FCA 188). For gross negligence penalties the statute goes further: s.163(3) puts the burden of justifying the penalty on the Minister, and Venne v The Queen (1984) requires "a high degree of negligence tantamount to intentional acting".
Collection While You Object — s.225.1
For individual income tax, serving an objection restricts CRA legal collection of the disputed amount — no court certificate, no requirement to pay, no seizure — until 90 days after the decision (Income Tax Act, s.225.1). The protection has hard edges Canadians should know: it does not cover payroll source deductions, it does not cover GST/HST debts (which arise under the Excise Tax Act and stay collectible), large corporations must pay half on assessment, and the CRA may still apply your refunds and credits against the debt. Interest accrues throughout at the prescribed rate plus 4% — 7% per annum for the April–June 2026 quarter, compounded daily.
Missed the Deadline — s.166.1
An application to extend the time to object can be made within one year after the objection deadline. The taxpayer must show that within the objection period they could not act or instruct another, or had a bona fide intention to object; that an extension is just and equitable; and that the application was made as soon as circumstances permitted (s.166.1). If the CRA refuses — or stays silent for 90 days — the taxpayer may apply to the Tax Court of Canada under s.166.2. After the one-year extension window closes, the right to dispute is generally lost for good.
After the Objection — Tax Court of Canada
If the Appeals Division confirms or varies the assessment, the taxpayer may appeal to the Tax Court of Canada within 90 days (s.169) — and may appeal directly once 90 days pass without a decision. The informal procedure covers disputes of $25,000 or less in federal tax and penalties per taxation year (excluding interest) or losses up to $50,000, with relaxed evidence rules. For a GST/HST assessment, use our GST/HST notice of objection template; to cut the penalties and interest themselves, our CRA taxpayer relief request; and to manage the balance while you dispute it, our CRA payment arrangement request.
Frequently Asked Questions
Object With Confidence — In Time, On the Right Grounds
Create your CRA notice of objection in minutes: issue-aware grounds, the Hickman Motors onus table, a numbered evidence schedule and the s.225.1 collection positioning, in formal Canadian letter format. Download the PDF free, or unlock Expert for the full grounds, assumptions and collections sections.
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