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14. Adjustment “denial” vs. notices of assessment

In Question 2 of the April 7, 2022, meeting, the CBA raised the issue of the CRA routinely issuing letters denying taxpayer adjustment requests rather than issuing a formal notice of assessment with no adjustments to which the registrant can readily file an objection. This can lead to issues where there is no administrative recourse to challenging a denial letter (or the CRA Appeals Division’s refusal to accept a resulting notice of objection).

The CBA asked whether the CRA would agree to issue reassessments rather than denial letters so that registrants can readily file objections. The CRA responded to this question by stating that it was working cross-functionally with Appeals and the GST/HST audit program to develop new policies and procedures to address this concern. The CRA is still routinely issuing denial letters instead of a formal notice of assessment with no adjustments.

Question

Can the CRA provide an update on the new policies and procedures being developed to address this concern? Is there a timeline for implementation of these policies and procedures?

CRA Comments

Due to other priorities, we do not have an update on the potential of issuing Notices of Reassessment for the denial of taxpayer requested adjustments at this time. We hope to have some additional information to share for the next CRA-CBA engagement.