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August 21, 2012

Canada Revenue Agency tax dispute statistics

Settlement, Withdrawal & Adjudication
By Peter Aprile
Canada Revenue Agency tax dispute statistics
Canada Revenue Agency tax dispute statistics
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The Canada Revenue Agency Appeals Branch provided our firm with the following statistics related to the number of tax dispute and tax litigation files along with the rates of settlement, withdrawal and adjudication.

In June 2012, the CRA reported that:

  • the CRA Appeals Branch receives between 80,000 and 110,000 notices of objection to dispute tax reassessments;
  • approximately 90% of taxpayer notices of objection relate to income tax matters;
  • approximately 92% of notices of objection are resolved at the objection stage (Nota bene. The CRA did not define “resolved” and the meaning of “resolved” is unclear e.g., the CRA did not break-out the percentage of taxpayers who abandoned their files and the percentage taxpayers who were successful in whole or in part and decided to discontinue their tax appeal);
  • in or about 8% of taxpayers who filed notices of objections to reassessments chose to appeal the CRA’s decision to the Tax Court of Canada; and
  • in or about 1/3 of the appeals in the Tax Court are abandoned, 1/3 are settled and 1/3 are adjudicated.

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