CRA Audits, Voluntary Disclosure and Tax Disputes: A Canadian Taxpayer Resource Centre
Plain-language guides for taxpayers and business owners dealing with a CRA audit, correcting past tax problems or disputing a CRA decision.
A letter from the Canada Revenue Agency, a return you now know was wrong, a reassessment you disagree with: each calls for a different response, and several come with deadlines that do not move. This resource centre is organized around those three situations. Find the one closest to yours, read that guide, and write down any date that applies to you.
The guides cover federal income tax and GST/HST rules administered by the CRA. They are written for individuals, self-employed people and owner-managed businesses. They explain how the process works and where the decision points are. They are not a substitute for advice on your own facts.
Which situation applies to you?
| If this sounds like you | Start here |
|---|---|
| The CRA has asked for receipts, records or an explanation of something on your return | Reviews, information requests and audits |
| An auditor has contacted you to schedule a meeting or sent a list of records to provide | How a CRA audit usually unfolds |
| You have income you did not report, or returns you never filed | Three ways to correct the record |
| The CRA wrote to you about a specific issue before you corrected it | Prompted, unprompted, or not voluntary at all |
| An auditor has proposed changes and you disagree | Responding to a proposal letter |
| You received a notice of reassessment | Objection deadlines |
| Someone from the CRA's criminal investigations area has contacted you | Audit or criminal investigation?, and speak with a lawyer promptly |
CRA letters, reviews, audits and reassessments
Not every letter from the CRA is an audit. Many ask you to support a particular deduction or credit, or to explain something on your return. An audit is a broader examination of your books and records; the CRA describes audits as part of how it keeps the tax system fair for everyone (CRA, What you should know about audits).
When an auditor intends to make changes, the CRA's practice is to explain them in a proposal and give you a chance to respond before anything is final (CRA, What you should know about audits). If your tax is then changed, you receive a notice of reassessment. A formal "requirement" is different again: it is a legal demand for information or documents under provisions such as section 231.2 of the Income Tax Act, not a request.
The CRA audits guide explains each of these, how far back the CRA can reassess, and how to deal with your records and the auditor.
Correcting past tax problems
If you know a past return was wrong, or you never filed, there are three broad routes: asking the CRA to change a return you filed, filing the returns that are missing, or applying to the Voluntary Disclosures Program (VDP). Individuals can generally ask the CRA to adjust a return for any of the previous ten calendar years (CRA, Change your return). A VDP application, if relief is granted, can bring penalty relief, partial interest relief and no referral for criminal prosecution for what is disclosed, but the tax itself must still be paid in full (CRA, IC00-1R7).
The VDP was revised for applications received on or after October 1, 2025. It now accepts some applications made after the CRA has raised a specific issue, at a lower level of interest relief, and it still excludes anyone already under audit or investigation on the matter being disclosed (CRA, IC00-1R7). The voluntary disclosure guide compares the three routes and explains the current rules.
Disputing a CRA decision
You can raise a disagreement at more than one stage: in response to an auditor's proposal, by filing a notice of objection after a reassessment, and, if the objection does not resolve it, by appealing to the Tax Court of Canada. The objection deadline is the one most often missed. For corporations and most other taxpayers it is 90 days after the notice of reassessment is sent; individuals (other than trusts) and graduated rate estates have until the later of that date and one year after their filing due date for the year (Income Tax Act, s. 165). GST/HST objections are governed by the Excise Tax Act and have their own 90-day period (Excise Tax Act, s. 301).
The disputes guide covers objections, collection while a dispute is under way, gross negligence penalties, privilege and the difference between an audit and a criminal investigation.
Featured guides
- How far back the CRA can reassess
- What changed in the Voluntary Disclosures Program on October 1, 2025
- Objection deadlines at a glance
- Solicitor-client privilege: what it covers and what it does not
If a deadline is running
Dates in CRA letters apply whether or not it is tax season. If you need more time to respond to an audit request, ask in writing before the date passes and keep a copy. Statutory deadlines, such as the deadline to object to a reassessment, are different: they cannot simply be extended by agreement, and a late objection requires a formal application for an extension of time (Income Tax Act, s. 166.1).
Speak with us
Beganyi Professional Corporation acts for individuals and owner-managed businesses in Ontario on CRA audits, voluntary disclosures and notices of objection. See our Tax Defence services or request a confidential consultation.
Sources
- CRA, RC4188 What you should know about audits
- CRA, IC00-1R7 Voluntary Disclosures Program
- CRA, Change your return
- Income Tax Act, s. 165 (objections)
- Income Tax Act, s. 166.1 (extension of time to object)
- Income Tax Act, s. 231.2 (requirements to provide information)
- Excise Tax Act, s. 301 (GST/HST objections)