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Published: March 6, 2020

Last Updated: March 17, 2020

Application under subsection 220(2.1) ITA Where Out of Time For Notice of Objection

The Federal Court of Canada ruled in Conocophillips Canada Resources Corp. v MNR T-1811-12 that CRA can waive the obligation to serve an income tax notice of objection under subsection 220(2.1) of the Income Tax Act. This means that in some circumstances even if the limitation period to file an Objection has been missed a Toronto tax litigation lawyer can apply to CRA to waive this requirement and in effect a late income tax objection can be processed.


"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."

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