Selected listed financial institutions (SLFI)

Goods and services tax / harmonized sales tax (GST/HST)

If you think we have misinterpreted the facts or applied the law incorrectly, you have the right to object to an assessment of the GST/HST. Filing an objection is the first step in the formal process of resolving a dispute. The time limit for filing an objection is 90 days from the date on the notice of assessment.

You or your authorized representative can file an objection by filling out Form GST 159, Notice of Objection (GST/HST), and sending it to the Intake Centre identified on the back of the form. You have to explain why you disagree and include all relevant facts and supporting documents.

You or your authorized representative can also submit your objection and supporting documents online at My Business Account, or Represent a Client, by selecting the “Submit documents” service.

For more information on the Submit Documents online service, go to Submit documents online.

Time Extension – Notice of Objection

You can apply for an extension of time to file your objection by writing to the chief of appeals at your local tax services office. Explain why you could not or did not file your objection on time.

Apply as soon as possible, but the application must be made within one year after the expiration of the time limit to file an objection.

Filing an appeal to the courts

If you disagree with the CRA’s decision resulting from an objection, you can appeal your assessment to the Tax Court of Canada (external link), either under the informal procedure or the general procedure. The time limit for filing an appeal is 90 days from the date on the notice. The Tax Court procedures are explained in GST/HST Memoranda series Chapter 31, Objections and Appeals. You can appeal the Tax Court’s decision to the Federal Court of Appeal (external link), and a judgment of the Federal Court of Appeal can be further challenged before the Supreme Court of Canada (external link), with the Court's permission.

Time Extension – Notice of Appeal

You can apply for an extension of time to file your appeal by making an application to the Tax Court of Canada. Explain why you could not or did not file your objection on time.

Apply as soon as possible, but the application must be made within one year after the expiration of the time limit to file an appeal.

Publication

• GST/HST Memoranda series, Chapter 31, Objections and Appeals

Quebec sales tax (QST)

Effective January 1, 2013, the CRA administers the QST applicable to SLFIs. If you think we have misinterpreted the facts or applied the law incorrectly, you have the right to object to assessments of the QST. Filing an objection is the first step in the formal process of resolving a dispute. The time limit for filing an objection is 90 days from the date on the notice of assessment.

You or your authorized representative can file an objection by filling out Form RC375, Notice of Objection (QST) for Selected Listed Financial Institutions, and sending it to the Intake Centre identified on the back of the form. You have to explain why you disagree and include all relevant facts and supporting documents.

You or your authorized representative can also submit your objection and supporting documents online at My Business Account, or Represent a Client, by selecting the “Submit documents” service.

For more information on the Submit Documents online service, go to Submit documents online.

Time Extension – Notice of Objection

You can apply for an extension of time to file your objection by writing to the Chief of Appeals at your tax services office or tax centre. Explain why you could not or did not file your objection on time.

Apply as soon as possible, but the application must be made within one year after the expiration of the time limit to file an objection.

Filing an appeal to the courts

If you disagree with the CRA's decision resulting from an objection to the QST matter, you can contest the decision by filing an appeal to the Québec Court of Appeal (external link). The time limit for filing an appeal is within 90 days after the date on which the Minister’s decision is sent.

A judgment from the Court of Québec may be further challenged in the Québec Court of Appeal (external link) and a judgment of the Québec Court of Appeal can be further challenged before the Supreme Court of Canada (external link), with the Court's permission.

Time Extension – Notice of Appeal

You can apply for an extension to file your appeal by making an application to the Court of Québec. Explain why you could not or did not file your objection on time.

Apply as soon as possible, but the application must be made within one year after the date on which the notice of the decision on objection is sent.

For more information, see the following publication:

Information on Judicial Recourse (COM-332-V) (external link)