If your CRA audit started or if your CRA objection was under review prior to March 2020, you probably have not heard from your CRA auditor or CRA appeals officer in a while.
This is because starting from March 16, 2020, as a result of the COVID-19 pandemic, the CRA operated in a so-called "critical services mode" and only the most urgent matters remained active while all other matters were held in abeyance. For the most part, CRA auditors, CRA Appeals officers, and CRA collection officers did not contact taxpayers.
This post is about how the CRA plans to re-start its operations.
Which CRA files were considered "critical" and remained active during the COVID-19 lockdown?
According to the CRA, they prioritized actions that were beneficial to the taxpayer or where taxpayers had indicated there was an urgency to advancing their audit. The CRA also focused on suspected fraud, higher dollar audits, audits close to completion, and those with a strategic importance. These matters advanced even during COVID-19 lockdown although the CRA may not have contacted the relevant taxpayers during that time.
When will the CRA start working on my file again?
On May 28, 2020, the CRA announced that it was "resuming a full range of audit work and adapting our practices to reflect the health and economic impacts of COVID-19."
On June 16, 2020, the CRA announced that starting June 26, 2020, it would start a transition from a "critical services mode" to a "business resumption mode".
What is a "business resumption mode?"
The CRA will be resuming its programs and activities in stages under its National Business Resumption Plan, which is still under development. More information about this plan should be available soon.
At this point, we only know that there will be a gradual transition to "normal" operations within the CRA. The full transition is likely to take "months, not days." Most CRA employees will continue working from home until at least the fall.
What does "business resumption mode" mean for my CRA audit or CRA objection?
Although we do not have the details of the CRA's National Business Resumption Plan and its stages, we tell clients to organize themselves and to be prepared to resume communications with the CRA as early as this summer.
Depending on the stage and the type or your CRA audit or CRA objection, you may receive a new request for information or be provided a new extended deadline for information requested before the pandemic/lockdown began. If your audit or objection was in the final stage prior to March 2020, you may receive a proposal letter or a final decision letter from the CRA.
My Notice of Reassessment was issued in March 2020 and my Notice of Objection was due June 13, 2020. Do I get an automatic extension of time to file because of the COVID-19 lockdown?
Yes, there is an extension of time but it is not indefinite and it expires on June 30, 2020.
For all objections that are due between March 18, 2020 and June 30, 2020, the CRA is extending the deadline to June 30, 2020. If your objection was due June 13, 2020, you only have until June 30, 2020 to file it.
How do I prepare to restart my communications with the CRA?
We strongly recommend to engage a tax professional for all your dealings with the CRA. At Advotax Law, we routinely help clients who are being audited or reassessed. Call us at 437-916-9000 for a free no obligation assessment of your case.
Nothing in this article constitutes legal advice and no solicitor-client relationship is created. If you require legal advice pertaining to your specific situation, please contact our tax lawyer.
Please note that this post is only as current as its publishing date indicates, but the relevant rules change constantly.
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