Overview: Missed CRA Email Notifications Can Cause Taxpayers to Lose CRA Objection Rights
A missed Canada Revenue Agency (CRA) email notification may cause Canadian taxpayers to lose CRA objection rights after a CRA tax reassessment. The CRA has moved most of its correspondence with taxpayers online. Audit proposal letters, notices of tax reassessment, and other correspondence are now typically posted electronically to a corporate taxpayer’s My Business Account or an individual’s My Account, rather than mailed on paper.
When new correspondence is posted, the CRA sends an email telling the taxpayer that they have correspondence to read in their account. The jurisprudence to date generally indicates that the CRA’s electronic notification and delivery process is sufficient to trigger applicable objection and appeal deadlines, even where the taxpayer claims not to have actually reviewed the correspondence. This approach was illustrated in DiPierdomenico v The King, 2023 TCC 146 [DiPierdo
