The appeal process for income tax and GST matters begin with a notice of objection. A notice of objection filed by a taxpayer states that the taxpayer disagrees with the contents of a notice of assessment or notice of reassessment issued by CRA. However, both the Income Tax Act and the Excise Tax Act (which contains the GST) share strict deadlines as to when a notice of objection can be filed.
A notice of objection can be filed, as of right, within 90 days of the date listed on the notice of objection. If a taxpayer fails to file a notice of objection within that 90 day period, a taxpayer may apply to CRA for an extension of time to file a notice of objection. The taxpayer has one year after the 90 day period has expired to apply for the extension of time. Accordingly, taxpayers have 15 months from the date listed on the notice of assessment or reassessment to file a notice of objection. After the 15 month window has elapsed, the taxpayer has no further ability to appeal.