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CRA Audit and Appeals vs Tax Court of Canada Appeals: Practical and Qualitative Distinctions

January 16, 2026 | Dylan Gervais

Tax disputes follow many stages and phases. Tax disputes with the CRA often begin with the audit process. As part of the audit process, the CRA may contact the taxpayer by letter or phone to gather information so that the taxpayer's assessment can be substantiated. After the audit process is complete, a reassessment may be issued where the CRA determines that an adjustment to the original assessment is warranted. The taxpayer may object to the reassessment by filing a notice of objection with the CRA. By objecting to the reassessment, the dispute is referred to CRA appeals, a separate division of the CRA that is meant to provide taxpayers a second review of their matter by an impartial appeals officer who was not part of making the assessment that is under dispute. Following the objection process, a taxpayer may appeal to the Tax Court of Canada. Each phase of a tax dispute from CRA audit and appeals to appealing to the Tax Court of Canada includes different considerations for taxpayers.

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