Appeals to Tax Court
If you are not satisfied with the decision of the CRA Appeals Division you may appeal that decision to the Tax Court of Canada. Your appeal to the Tax Court must be filed within 90 days of the CRA Appeals Division rendering its decision (not the date you received the decision). We recommend you not delay this process, that you file in a timely manner and that you do so with the assistance of a professional tax advisor.
Appeals to the Tax Court of Canada are not simple matters for the layperson to navigate. There are different procedures, various filing costs involved and the CRA will be represented by a lawyer assigned by the Justice Department of Canada.
Either the taxpayer or the CRA may appeal the Tax Court decision to the Federal Court of Appeal and then possibly to the Supreme Court of Canada. Various requirements and deadlines apply for such appeals and professional advice is important.