Last March 18th, the CRA announced the suspension of the vast majority of audit activities as a result of the COVID-19 pandemic. How quickly things change!

On May 28, 2020 the CRA updated its website to indicate that it would be "resuming a full range of audit work", with the CRA's initial audit focus being large dollar value audits, audits which were close to completion on March 18, 2020, audits with "strategic importance" and audits where some other form of "urgency" exists.

In the circumstances, taxpayers or registrants who had audits underway on March 28, 2020 may consider reaching out to their CRA Auditor in the coming weeks to try and determine where their audit file falls among the CRA's priorities, and when they can expect to begin dealing with the CRA Auditor once more.

CRA Appeals – Most Objections Still being Held in Abeyance - While the CRA Audit Division begins to ramp up its activities, it appears that the CRA Appeals Division will be continuing to hold most Notices of Objection in abeyance – with a possible the exception for Objections relating to entitlement to benefits and credits (which are proceeding as a "critical service").

To date there is no indication when this "abeyance" will end and the CRA Appeals division will resume its consideration of all Objections.

Notices of Objection Due? – CRA Says File by June 30, 2020 - With respect to Notices of Objection which were due to be filed with the CRA between March 18, 2020 and June 30, 2020, the CRA has indicated "we are effectively extending the deadline to June 30, 2020".

The precise mechanism the CRA is relying on for this "extension" is not entirely clear as this is a statutory deadline, and taxpayers or registrants who have a Notice of Objection coming due during this time period would be wise to obtain professional advise with respect to their obligations under the relevant legislation.

With June 30th fast approaching, and no indication that the CRA will issue any further extensions to this June 30th date, taxpayers and registrants should ensure they do what they can to file on time, or they risk missing out on whatever administrative relief the CRA may be granting.

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