When a taxpayer is in disagreement with an assessment issued by taxation authorities, he has the right to contest such assessment before the administrative courts of the various taxation authorities. It is sort of an administrative appeal.
Usually within a 90-day period following the issuance of a contested assessment, the taxpayer can file with the taxation authorities a “notice of objection”. In such objection notice, le taxpayer fully explains the reasons why he thinks the assessments is ill founded.
The “notice of objection” will be dealt with by an objection officer of the applicable taxation authorities. Such agent will scrutinize the taxpayer’s contentions, as well as those of the auditor.
At the objection stage, it is therefore essential that a complete file be submitted, which shall include a proper statement of the facts and refer to the relevant statutes and interpretation bulletins, as well as to appropriate caselaw.
Louis Sirois, Tax Lawyer