The Canada Revenue Agency (“CRA”) launched a 100-day Service Improvement Plan on September 2, 2025, under direction from the federal government to “fix unacceptable wait times and service delays” by December 11, 2025. 

This rapid initiative was a response to widespread frustration from taxpayers and professionals alike over long call hold times, slow processing of tax requests, and difficulties accessing CRA services. Over roughly three months, the CRA implemented a suite of measures to boost service capacity and modernize service tools quickly. This article outlines the core objectives of the 100-day plan, results achieved in that timeframe, and the areas that remain incomplete or unsatisfactory.

Core Objectives of the 100-Day Plan

The 100-day plan focused on four primary objectives designed to improve the taxpayer experience in the short term:

• Improve Call Response Capacity and Responsiveness: Significantly increase the percentage of taxpayer phone calls answered, reducing excessive wait times and repeat calls. This included hiring or reallocating staff to boost contact centre coverage.
• Expand Digital Self-Service Options: Enhance and promote online tools (e.g., My Account portal, chatbots, and web self-service content) so more Canadians can access information or complete tasks independently without needing to call.
• Address Root Causes of Service Delays: Tackle the underlying backlogs and processing delays (for example, in tax return adjustments, benefit claims, and other requests) that lead taxpayers to call in the first place. This involved streamlining processes and adopting new technologies (such as automation and AI) to accelerate workflows.
• Accelerate Service Modernization: Fast-track the introduction of new technologies and service channels (such as callback systems, enhanced phone capabilities, and account security enhancements) to deliver more accessible, user-friendly, and efficient service interactions.

The CRA published these objectives as a roadmap to improve service in the “the very short term,” committing to report progress on a dedicated web page throughout the 100 days. The overarching goal was to demonstrate measurable service improvements by the end of the period and to begin restoring public trust in the CRA’s client service.

Key Achievements in the First 100 Days

By December 11, 2025, the CRA announced that it had made “considerable and marked progress” on all four priority areas of the plan. Notable achievements include:

Call Centre Capacity and Responsiveness

• The CRA more than doubled its call answer rate, increasing the share of unique callers reaching an agent from about 35% in the summer of 2025 to over 70% by the end of the 100 days. Weekly tracking data indicates an improvement from 35% of calls answered in early July 2025 to 82% in the first week of December 2025, exceeding the plan’s 70% target. To accomplish this, the CRA extended term contracts and rehired approximately 1,250 contact centre employees, bolstering front-line staff to reduce wait times. 
• The CRA also implemented a new scheduled callback system for account access issues. Over 59,000 Canadians received scheduled callback appointments instead of waiting on hold. The tool enabled people to regain access to locked CRA accounts without lengthy waits. These efforts significantly eased the telephone bottlenecks that had plagued the CRA.

Digital Self-Service Tools

• The CRA introduced and improved multiple online services to let taxpayers help themselves. For example, as of October 20, 2025, a new “Manage Balance” self-service feature in CRA’s online portal allows individuals with tax debt over $1,000 to set up payment plans or make payments without speaking to an agent. Within weeks of launch, roughly 500,000 to 600,000 eligible users accessed this tool. In one week in early December, taxpayers used it 23,733 times to make payments or arrangements online instead of calling. 
• The CRA also enabled locked-out users to re-register and regain access to their online accounts independently (as of late October), reducing calls to reset credentials. 
• GenAI, the CRA’s online chatbot, was expanded to handle a broader range of questions, including more complex business tax topics and basic queries.
• The document verification service has made CRA account registration quicker, with 88% of new users gaining access in October 2025, mitigating approximately 300,000 phone calls per year.
• Updates to Canada.ca tax pages to clarify benefits, credits, and processing timelines

Tackling Backlogs and Delays

• The CRA targeted specific backlogs that were driving complaints. The CRA identified the following as key areas driving complaints: processing of individual T1 tax adjustments, Disability Tax Credit (“DTC”) applications, and Canada Child Benefit claims. A targeted plan was implemented to address these areas.
• By reallocating some customer service agents to work on the DTC backlog, the CRA processed an additional 23,000+ DTC requests within 100 days (in addition to normal volumes) without sacrificing its call-answer rate goal. 
• CRA systems were enhanced to auto-process more transactions. As of October, a new automation for tax adjustments was implemented to process approximately 115,000 additional adjustment requests per year automatically. This is expected to reduce wait times for Canadians awaiting reassessments significantly.

Service Modernization Initiatives

• In 100 days, the CRA implemented changes to its phone service as recommended by the Taxpayers’ Ombudsman (an independent watchdog for service issues). These included testing a new call-scheduling system and improving phone routing to ensure payment-related calls are routed directly to specialized agents. These changes are estimated to eliminate about 95,000 call transfers per year and get callers to the right help faster. 
• The CRA additionally began work on a modernized contact centre platform (a significant overhaul of phone technology and processes). Security and access improvements were also planned, including the recent introduction of mandatory multi-factor authentication for online accounts to reduce lockouts. 

Remaining Challenges and Incomplete Areas

Despite the positive metrics and accomplishments above, not all problems were solved in 100 days. Both the CRA’s own leadership and external observers acknowledge that significant service issues remain. Key areas of ongoing concern include:

Call Accuracy and Information Quality

Improving call-handling speed is meaningless if the information provided is incorrect. In October 2025, the Auditor General (“AG”) released a report revealing serious accuracy issues in CRA call centres. In test calls, agents answered only 17% of basic personal tax questions accurately, and just over 54% of business-related questions accurately. This alarming finding suggests that many callers may still receive wrong or incomplete answers, potentially leading to mistakes and frustration.

Processing Delays and Backlogs Persist

The 100-day plan made a dent in backlogs, but significant delays persist in certain areas, particularly for complex cases. The Taxpayers’ Ombudsperson noted at the plan’s conclusion that “significant delays in processing complex T1 adjustment requests” still require attention.

Short-Term Plan vs. Long-Term Change

By design, the 100-day plan was a quick fix or “Band-Aid” solution, and officials concede that deeper, long-term reforms are needed. The federal government has already begun formulating a multi-year (3–5-year) plan for the CRA to ensure continued improvements in service standards and call centre performance beyond this initial sprint. 

CRA leadership acknowledges that 100 days were insufficient to address systemic problems. Some of the plan’s more ambitious components (like the modernized phone platform and additional automation) will not fully materialize until 2026 or later. This means Canadians may not yet feel all the intended benefits. There is also recognition that cultural and structural issues within the CRA contribute to service problems, which a 3-month effort alone cannot resolve.

Conclusion and Summary of Outcomes

Ultimately, the CRA’s 100-day plan somewhat succeeded in meeting its immediate service targets, wait times are down, and new self-help channels are in place, which is a tangible win for Canadians contacting the CRA. However, not all objectives were fully achieved in the tight timeframe. 

The CRA has signalled its commitment to build on the 100-day plan’s momentum, heading into the 2026 tax season with plans for additional hiring, better training, and further automation. Canadians will be watching to see if these efforts translate into a sustained high level of service.

Businesses often ask the following question: how long does Canada Revenue Agency (CRA) have to collect unpaid taxes. The answer lies in the CRA collections limitation period, a legally defined timeframe during which the Canada Revenue Agency can enforce tax debt collection. Generally, the CRA’s window to collect is either 6 or 10 years, depending on the type of tax debt. After this period, the debt becomes statute-barred – meaning CRA is typically prohibited from further enforcement.

Collection Periods by Tax Debt Type

• Corporate Income Tax: 10-year collection limitation period (for corporate income tax debts), starting 90 days after the CRA issues a Notice of Assessment or reassessment.
• GST/HST Remittances: 10-year limitation period for GST/HST debts, beginning the day after the Notice of Assessment is sent.
• Payroll Source Deductions: 6-year limitation period for unremitted payroll withholdings, starting the day after the CRA issues a Notice of Assessment.

When the Clock Starts and Resets

The 6- or 10-year countdown can be restarted or extended by certain actions. Any payment, written acknowledgment of the debt, or new action by CRA (for example, issuing a garnishment or registering the debt as a judgment in Federal Court) will restart the clock. Likewise, if CRA issues a reassessment – say, after an audit or discovering unreported income – a fresh limitation period begins from that new assessment date. Some events also pause the countdown: for example, if a taxpayer files a Notice of Objection, declares bankruptcy, or leaves Canada, the clock is suspended until that event concludes.

After the Limitation Period Ends

Once the CRA tax debt collection rules have run their course with no interruptions, the CRA is generally barred from taking further collection action on that debt. However, the debt itself still exists, and voluntary payments can be made even after the deadline passes (such payments are generally not expected to restart the expired limitation period).

Form T1135 – the Foreign Income Verification Statement – must be filed by any Canadian resident taxpayer (individual, corporation, or certain trust/partnership) who at any time in a year owns specified foreign property with a cost of more than C$100,000. This requirement is intended to ensure taxpayers report foreign-source income and assets. Understanding what constitutes “specified foreign property” (SFP) is critical, as it determines whether a T1135 filing is required. Below, we examine the statutory definition of SFP under the Income Tax Act (Canada) (ITA). We also note considerations for individual vs. corporate filers and briefly mention the availability of the Voluntary Disclosures Program for those who have failed to file form T1135.

Statutory Definition under the Income Tax Act (Canada)

The term “specified foreign property” (SFP) is defined in subsection 233.3(1) of the ITA. The definition encompasses a broad range of assets held outside Canada or in foreign entities, and generally include the following key categories:

• funds or intangible property, or for civil law incorporeal property, situated, deposited or held outside Canada (e.g. cash held in foreign bank accounts, patents or copyrights situated abroad. According to the CRA, stock of Canadian-resident companies if held by the taxpayer through a foreign broker or custodian outside Canada),

• tangible property, or for civil law corporeal property, situated outside Canada (e.g. precious metals held outside Canada),
• a share of the capital stock of a non-resident corporation,
• an interest in a non-resident trust (e.g. an ownership interest in a foreign trust, such as a foreign mutual fund trust, acquired by purchase or investment),
• an interest in a partnership that owns or holds specified foreign property (the CRA provides that if a Canadian taxpayer is a partner in a partnership that itself owns SFP, the partnership interest is SFP (unless the partnership is itself required to file a T1135 as a “specified Canadian entity”),
• an interest in, or right with respect to, an entity that is non-resident (this captures convertible or exchangeable instruments, options, etc. related to foreign assets),
• indebtedness owed by a non-resident person (e.g. funds lent to a non-resident person or entity, including foreign government or corporate bonds, mortgages, notes, and other receivables from non-residents), and
• an interest in, or for civil law a right in, or a right — under a contract in equity or otherwise either immediately or in the future and either absolutely or contingently — to, any property (other than any property owned by a corporation or trust that is not the person) that is specified foreign property (for example, a life insurance policy issued by a foreign insurer and gold certificates outside Canada could be SFP).

However, the ITA also excludes several categories of property from the definition of SFP. Excluded properties generally (i.e. not considered SFP) include:

• property that is used or held exclusively in the course of carrying on an active business of the person or partnership (determined as if the person or partnership were a corporation resident in Canada) (e.g., if a Canadian corporation owns a warehouse or equipment in a foreign country that is used solely for its active business operations, that asset is not SFP),
• a share of the capital stock or indebtedness of a non-resident corporation that is a foreign affiliate of the person or partnership for the purpose of section 233.4 of the ITA (such investments may need to be reported under separate foreign affiliate rules and Form T1134, not on T1135),
• an interest in, or indebtedness of, a non-resident trust that is a foreign affiliate of the person or partnership for the purpose of section 233.4 of the ITA,
• an interest in a non-resident trust that was not acquired for consideration by either the person or partnership or a person related to the person or partnership,
• an interest in a trust that is described in paragraph (a) or (b) of the definition exempt trust in subsection 233.2(1) of the ITA, or that would be described in paragraph (b) of that definition if it was drafted a certain way):
• an interest in a partnership that is a specified Canadian entity,
• a right with respect to, or indebtedness of, an authorized foreign bank that is issued by, and payable or otherwise enforceable at, a branch in Canada of the bank, and
• personal-use property of the person or partnership (e.g.  a vacation home owned abroad that the taxpayer uses primarily for personal vacations (and not to earn income) is considered personal-use property and is not reportable on T1135). The CRA interprets “primarily” as more than 50% personal use.

In summary, the statutory definition casts a wide net over foreign assets, but it also provides for significant carveouts. Tax professionals should first apply this definition to determine if a client’s foreign holdings are SFP. If the total cost of all such SFP exceeds C$100,000 at any point in the year, a T1135 filing is required.

Beneficial Ownership – Chan v. The Queen (2022 TCC 87)

One notable case is Chan v. The Queen, 2022 TCC 87. In this Tax Court decision, the taxpayer (Mr. Chan) had opened a foreign bank account in his own name in China, but did so on behalf of his father and with the father’s funds. The CRA assessed penalties for failure to file T1135, assuming Mr. Chan owned the Bank of China account. The Tax Court, however, found that Mr. Chan was not the beneficial owner of the account assets – his father was. The judge concluded that although the account was in the son’s name, the father provided all the funds and exercised all control and benefit from the account. Because the son did not actually own (beneficially) the foreign property, he was not required to file Form T1135 for that account. This ruling underscores that who “owns” specified foreign property is a substantive question of fact. Simply being listed as an account holder or legal owner is not conclusive if, in reality, the asset is held in trust for someone else.

Considerations for Individuals vs. Corporations as T1135 Filers

Both individual taxpayers and corporations (as well as trusts and partnerships) can have T1135 filing obligations, but the nature of their foreign properties and applicable exclusions may differ:

• Individuals: Common SFP for individuals include foreign bank accounts, investment accounts, foreign stocks or bonds, and foreign real estate. A key consideration is the personal-use property exclusion, which often applies to individuals’ vacation homes or personal assets abroad. Tax advisors should determine if a client’s foreign real property is primarily for personal use (excluded) or if it’s an income-producing rental or investment (included).
• Corporations: Canadian corporations must file T1135 for SFP they own above the threshold, and they often encounter the active business property exception. If a corporation’s foreign assets are integral to its active business operations (e.g. overseas branch office, machinery, inventory abroad), those assets are generally not SFP. Corporations commonly have foreign affiliates, which are excluded from SFP. Corporate filers should also note that the T1135 deadline for corporations aligns with their tax return due date (6 months after fiscal year-end), which differs from the individual deadline.

Regardless of taxpayer type, it’s important to document the purpose and use of each foreign asset. For instance, if a corporation claims an asset is used 100% in active business (to exempt it from SFP), maintaining evidence of that business use is prudent. Similarly, individuals claiming personal-use status for a property should be prepared to support the claim (e.g. usage logs). In all cases, keeping track of cost amounts of foreign properties is essential, since the $100,000 threshold is based on cumulative cost, not market value.

Voluntary Disclosures and Compliance

If a taxpayer realizes they failed to report specified foreign property when required, they should be aware of the CRA’s Voluntary Disclosures Program (VDP). The VDP allows taxpayers to come forward to correct previous omissions or errors, including unfiled T1135 forms, in order to avoid or reduce penalties. The CRA explicitly encourages taxpayers who have not filed or who have filed incomplete information to use the VDP to get back into compliance. A valid disclosure that meets the program’s conditions may result in reduction of penalties and interest.

Conclusion

Specified foreign property is defined broadly under Canadian tax law, and the scope of Form T1135 is extensive. By understanding the inclusions and exclusions in the definition, advisors can ensure that individuals and corporations meet their compliance obligations.

Annual Caseload and Filing Trends

The Tax Court of Canada (TCC) hears hundreds of tax dispute appeals each year. In recent years, the number of new cases (appeals) filed annually has been in the low-to-mid thousands, with notable fluctuations. In the fiscal year 2022–23, a total of 3,230 appeals were instituted or filed. This represented a slight decrease from 3,426 cases filed in 2021–22, but a significant rebound from the 2,325 cases filed in 2020–21, when filings dropped (likely due to pandemic-related disruptions). Prior to 2020, the Court’s caseload was higher – for example, 5,211 new cases were filed in 2018–19, and 4,684 in 2019–20. This trend indicates that after a sharp dip in 2020–21, tax dispute filings have recovered towards pre-pandemic levels, though they remain somewhat below the peak numbers seen in the late 2010s.

Alongside new filings, the Court has been actively processing and disposing of cases. In 2022–23, the TCC disposed of 3,876 cases (through judgments, settlements, withdrawals, etc.), which actually exceeded the number of new filings that year. This helped reduce the backlog of active cases. As of March 31, 2023, there were 10,273 active proceedings pending before the Tax Court, down from 11,504 a year earlier. These figures suggest the Court improved its clearance rate, closing more cases than were opened in that period. By comparison, active caseloads in the late 2010s were around 10,500 cases, indicating that the overall pending volume has been relatively stable, with some pandemic-related variability.

Types of Tax Issues in Dispute

The Tax Court’s jurisdiction covers a range of federal tax matters, and the vast majority of cases involve income tax. As of the most recent data, about 81% of pending appeals are income tax disputes. For example, at March 31, 2023, there were 8,328 active Income Tax Act (Canada) cases in the Court’s inventory (out of 10,273 total). The next largest category of appeals relates to federal sales tax: roughly 15% of cases involve Goods and Services Tax/Harmonized Sales Tax (GST/HST) matters (approximately 1,584 active GST/HST cases at the same date..

A smaller share of the Court’s workload involves other statutes. Only about 3% of active proceedings are appeals under the Employment Insurance Act or Canada Pension Plan (e.g. disputes over EI premiums or CPP contributions/benefits), totaling 300–350 cases in recent years. The remainder (only a few dozen cases) fall into “other” categories (such as excise taxes, or other less common federal tax issues). These proportions have been relatively consistent in recent years – income tax issues dominate the docket, followed by GST/HST, with only a marginal number of cases concerning other taxes or programs.

Profile of Appellants: Individuals vs. Corporations

Both individual taxpayers and corporate taxpayers bring appeals to the Tax Court. The Court provides two procedural streams which tend to correlate with the type of appellant and size of dispute. Individual taxpayers (including unincorporated small businesses) frequently use the Informal Procedure, which is designed for simpler, lower-value cases. The informal track has no filing fee and does not require the appellant to hire a lawyer, but it is limited to disputes involving smaller amounts. This option is popular among individual appellants because of its accessibility and lower cost. In contrast, larger businesses (and some individuals with high-value disputes) proceed under the General Procedure, which has formal court processes (and typically involves counsel) and no monetary limit on the amount in dispute.

While official statistics do not specifically break down the proportion of cases by taxpayer type (individual vs. corporate), the nature of the procedural choices provides some insight. Many of the TCC’s appeals – especially those under the informal procedure – are launched by individual taxpayers challenging personal income tax assessments or GST credits. Corporate tax disputes (often involving significant amounts or complex issues) are fewer in number but can be prominent in the general procedure docket. Both categories of taxpayers are represented in the Court’s caseload. For instance, the Canada Revenue Agency (CRA) notes that when a taxpayer (individual or business) disagrees with an assessment and exhausts the internal objection process, they may appeal to the Tax Court under either the informal or general procedure as appropriate In practice, this means the TCC sees everything from self-represented individuals contesting modest personal tax adjustments, to large corporations litigating sophisticated tax avoidance or accounting issues.

Case Resolutions

Most tax appeals are resolved without proceeding to a full trial in court. Official analyses have shown that a substantial portion of Tax Court cases end in settlements or other resolutions before a judge issues a verdict. For example, in 2022–23 the Court held hearings (i.e. cases “heard in court”) in 713 cases, while 3,876 total cases were disposed that year. This implies that roughly four out of five dispositions were resolved through settlements, withdrawals or other non-trial closures, with only about 18% of cases requiring a court hearing and judgment. It is clear that settlement negotiations and alternative resolution mechanisms (such as settlement conferences facilitated by the Court’s process) play a major role in tax litigation, allowing many disputes to be concluded without a formal trial.

In summary, the Tax Court of Canada’s latest official statistics show a moderate volume of new cases each year (on the order of a few thousand, with recent increases post-2020), and a broad range of tax matters dominated by income tax issues. Appeals are brought by both individual Canadians and corporations, through procedures tailored to the size of the dispute. Most cases are resolved through settlements or other means before trial, reflecting an emphasis on dispute resolution; only a fraction proceed to a full hearing.

Scenario: A small corporation has been reassessed by the Canada Revenue Agency (CRA) for income tax, but the owner missed the 90-day deadline (plus the one-year extension) to file a notice of objection. Normally, missing this deadline means the tax debt is final and unchallengeable by the corporation. Faced with an unpayable tax bill, the owner puts the corporation into bankruptcy. What happens next, and is there any way to dispute the tax debt now?

Section 160 – Liability for Transfers to Non-Arm’s-Length Parties

Generally, when a tax debtor transfers property to a related or non-arm’s-length recipient for less than fair market value, section 160 of the Income Tax Act (Canada) (ITA) allows CRA to pursue the recipient for the transferor’s tax debt. In effect, the recipient becomes liable for the tax debt up to the lesser of the value of the transferred asset (minus the consideration received by the transferor) and the amount of the tax debt. For example, if a corporation owing taxes paid a dividend or transferred an asset to its shareholder (a non-arm’s-length person) without equivalent consideration, CRA can generally assess the shareholder personally under section 160 for the corporation’s income tax arrears (to the extent of the undervalued transfer). The shareholder and the corporation are then jointly and severally liable for that amount.

In our scenario, once the corporation is bankrupt (and cannot pay its tax debt), CRA often turns to such derivative assessments. The business owner might receive a section 160 assessment holding them personally liable for the corporate tax debt, especially if they received any funds or assets from the company for little or no consideration.

Defending a Section 160 Assessment – Contesting the Tax Debt

Importantly, being assessed under section 160 gives the individual a fresh chance to dispute the underlying tax debt. The section 160 assessment is a separate assessment against the transferee (the owner), who has their own right to object and appeal. Canadian courts have confirmed that a person assessed under section 160 must have a full right of defence to challenge the assessment made against the person, including an attack on the primary corporate assessment on which the person’s assessment is based. In other words, even though the corporation missed its objection deadline, the transferee can still argue that the corporation did not actually owe the amount of tax in the first place.

When responding to a section 160 assessment, several defences can be raised, including (but not limited to):

• No Tax Debt or Lower Tax Debt: The original taxpayer (e.g. the corporation) did not owe the assessed taxes – meaning the underlying tax assessment was incorrect. This is effectively challenging the basis of the tax debt.
• Valid Consideration: The transfer in question was not a gift or below-value transfer (for example, it was repayment of a loan or the recipient paid fair market value), so section 160 should not apply.
• Overstated Value: The property’s value was lower than the CRA assumed, reducing the transferee’s liability.

If any of these succeed, the section 160 assessment can be reduced or eliminated. Notably, lack of knowledge of the tax debt is not a defence – liability under section 160 can apply even if the transferee was unaware of the tax owing.

Practical Takeaways

This strategy – letting the corporation go bankrupt and dealing with a section 160 assessment – is a last resort. It underscores a peculiar quirk of tax law: a related-party recipient can get their “day in court” on the original tax issue, even if the primary taxpayer lost that right. However, invoking this strategy is risky and can lead to personal liability. The better course is always to file timely objections to tax assessments to avoid such predicaments. If you do find yourself facing a section 160 assessment after a missed objection, seek professional tax advice.