A typical tax dispute begins with the CRA conducting an audit. If the CRA does not agree with the amount of tax that you initially reported owing, they will issue you a Notice of Reassessment.
Once the CRA has issued the Notice of Reassessment (and before the time deadline), you can file a Notice of Objection. (We recommend you call us before doing so).
The CRA will assign your objection to an Appeals Officer, who is different from the auditor. You will have an opportunity to make submissions to the Appeals Officer to convince them that the auditor got it wrong.
If the Appeals Officer does not fix the auditor’s errors. You can file a Notice of Appeal with the Tax Court of Canada.
Our experience is that, ultimately, about 95% of Notices of Appeal settle before trial, but if necessary, you can have a judge of the Tax Court make an independent ruling on your appeal.