Objections and appeals – Registered charities and other qualified donees

If you think we have misinterpreted the facts or applied the law incorrectly, you have the right to object to a notice or an assessment.

This page provides guidance for qualified donees and certain applicants refused registration as a qualified donee. These include:

• Registered charities 
• Registered national arts service organizations (RNASOs)
• Registered Canadian amateur athletic associations (RCAAAs)
• Registered journalism organizations (RJOs)
• Registered municipalities
• Registered municipal or public bodies performing a function of government in Canada
• Registered universities outside Canada
• Registered foreign charities that have received a gift from His Majesty in right of Canada
• Registered low-cost housing corporations for the aged

Applicants for registration as a charity, national arts service organization,  Canadian amateur athletic association, journalism organization, low-cost housing corporation for the aged, or a municipal or public body performing a function of government in Canada, may also object if they are refused registration.

The first step in the formal process of resolving a dispute is filing an objection. The time limit for filing an objection is 90 days from the date on the notice. 

You can file an objection by writing to:

Assistant Commissioner
Appeals Intake Centre
Post Office Box 2006, Station Main
Newmarket ON L3Y 0E9

If you are a registered charity, registered amateur athletic association or registered national arts service organization and have an associated RR account, you can file an objection online:

• using the "File a formal dispute (Notice of Objection)" service at:
  • My Business Account
  • Represent a client, if you are an authorized representative

In all cases, you have to explain why you disagree with the notice or assessment issued and include all relevant facts and supporting documents.

Filing an appeal to the courts

If you disagree with the CRA's decision resulting from an objection in Category A, you can appeal to the Federal Court of Appeal. The time limit for filing an appeal is 30 days from the date on the notice. The Federal Court of Appeal judgment can, in turn, be challenged before the Supreme Court of Canada, with that Court's permission.

If you disagree with the CRA's decision resulting from an objection in Category B, you can appeal to the Tax Court of Canada, either under the Informal Procedure or the General Procedure. These procedures are explained in Appealing Income Tax Act Assessments and Notices in respect of Registered Charities, and other qualified donees, to the Tax Court of Canada. The time limit for filing an appeal is 90 days from the date on the notice. If you are not satisfied with the judgment of the Tax Court of Canada, you can appeal to the Federal Court of Appeal, and a judgment of the Federal Court of Appeal can be further challenged before the Supreme Court of Canada, with that Court's permission.

Registered charities may object to notices or assessments regarding:

Category A

• designation
• intention or decision to refuse, annul or revoke registration

Category B

• income tax and penalties
• suspension of tax-receipting privileges

RCAAAs, RNASOs and RJOs may object to notices or assessments regarding:

Category A

• intention or decision to refuse or revoke registration

Category B

• income tax penalties
• suspension of tax-receipting privileges

Other qualified donees may object to notices regarding:

Category A

• decision to refuse registration of:
  • low-cost housing corporations for the aged
  • municipal or public bodies performing a function of government in Canada
• intention to revoke registration of all other qualified donees

Category B

• suspension of tax-receipting privileges

For more information, you may leave a message in the voice mailbox at 613-670-7348.