Court Opines on CRA’s Cryptic Information to Taxpayers
What constitutes a notice of objection and why does the CRA not clearly and unambiguously state appeal rights and procedures when issuing reassessments?
In a very recent FCA decision, the Court answered the first question and further highlighted the problematic nature of the CRA’s general and unclear statements in reassessments regarding objection rights.
[15] The Supreme Court of Canada emphasizes the importance of removing barriers that impede access to justice: Hryniak v. Mauldin, 2014 SCC 7 at para. 1. Many taxpayers simply cannot afford to engage tax professionals to assist them in dealing with the CRA. Yet, in this case, rather than clearly informing the appellant about the critical importance of the timely filing of a notice of objection, her notices of reassessment included general statements about where to find more information about her reassessment and objecting to it, and how to contact the CRA. While I attribute no ill will to the CRA or its representatives, simply put, that does not reflect the stakes. I am certain the CRA can and should do better.
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