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ARTICLE · 13 APRIL 2026

Notice Of Objection Window | What Carries Forward

Counter Tax Litigators LLP
Counter Tax Litigators LLP
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Counter Tax Litigators LLP

Counter Tax Litigators LLP

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A CRA Notice of Reassessment has been issued. The deadline to file a Notice of Objection is now active. Management is deciding how to respond.

CanadaTax
Counter Tax Litigators
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A CRA Notice of Reassessment has been issued. The deadline to file a Notice of Objection is now active. Management is deciding how to respond.

At this stage, management can still shape the response. That changes once it is filed.

The objection is often treated as procedural. A filing that preserves rights while positions continue to develop.

It does more than that.

The objection places part of the dispute on the record:

  • which issues the company advances
  • how those issues are framed
  • what is included and what is left out

Appeals reviews that record. If the matter proceeds, the court relies on it. Later positions are assessed against it.

The dispute does not reset as it moves. It is carried forward and judged across stages and institutions.

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