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The Canada Revenue Agency (CRA) sorts formal tax disputes (objections) into defined complexity levels – Low, Medium, High – each with its own expected processing timeframe. Understanding these categories and timelines is crucial for tax practitioners managing client disputes. Below is an overview of each complexity level and typical resolution times for income tax objections. Low Complexity Cases Low complexity income tax objections involve straightforward is…
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 impl…
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 f…
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 re…
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 fil…