CRA appears to be in the process of making changes to its “represent a client” portal for individuals, a tool used by tax professionals to review and summarize their clients’ tax issues. The Agency is now providing a beta version of the client overview page. While most of the changes are cosmetic, the CRA appears to be changing the way that it deals with some common tax issues electronically.
As of writing, over the past 30 days, the CRA login page has been viewed 4,868,605 times, as per the Government’s data. The CRA’s site is visited the second-most of any sector of the federal government, second only to Immigration, Refugees and Citizenship Canada.
The Trudeau government has stressed tax administration and collection issues, and this emphasis is felt throughout our practice. For example, we have already noticed a surge in new housing rebate audits that may be related to an announcement for increased funding in the 2019 budget.
The 2018 budget particularly stressed improvements to the CRA’s internet services and reducing the processing time for objections. We suspect that this emphasis contributed to recent changes in the use of electronic services. The introduction of the Beta Version of the CRA’s page looks to simplify scanning and printing and allows representatives to expand and collapse sections. Not particularly substantive, but potentially welcome changes.
We have also seen more significant changes. CRA appears to be significantly stepping up its “triage” program for notices of objection. CRA outlines its service standards here.
These categories are somewhat vague, and the “medium complexity” tier contains a very wide variety of issues. Generally, when an objection is considered low complexity, it will be reviewed very quickly, and CRA will request evidence and a response in very short order. Low complexity, and perhaps the lower end of medium complexity, are increasingly placed into “triage”, where soon after filing an agent will once-over the objection and request supporting evidence. The hope is that the agent ultimately reviewing the case will have all they need to decide.
The increased use of triage creates both opportunities and hurdles for us and our clients. Where an objection is triaged and we have what we need to resolve it, this streamlined process means that we can get disputes behind clients quickly.
However, particularly when near the end of a limitations period, it can make sense to object while a client looks for documents, speaks with others about evidence, or accountants prepare the relevant returns. In these cases, an extended objection period can be necessary for us to meet the objection deadline while locating or preparing the information needed for a successful resolution. Shorter response times, particularly when changed over a short period of time, compress the timeline for this, which creates risk if we encounter delays.
Placing some issues in the “low complexity” tax objection category, or the agency taking on staff to step up enforcement, can cause issues. The agents handling these issues may be more junior, and as such provided with less latitude to look beyond the four corners of a client’s receipts or other documents. Some issues that may be considered low complexity, such as new housing rebates and employment expenses, can involve technical edge cases.
We have also noticed an uptick in the CRA’s use of the “mail” function of its online services over the course of 2019. While this service used to be somewhat restrained and of limited use, the CRA appears to be uploading electronic copies of a broader range of documents to the online portal, including those relating to objections, reviews, and collections.
Particularly for clients who spend much of their time away from home, or who are less technologically inclined, this is a very welcome change, as we can more frequently review documents sent to them without as much of a reliance on scanning or the postal system.
The CRA’s reliance on automatically generated messages can lead to confusion and stress when the system does not update in real time (for example, the CRA sending collections notifications before they update the amount that they can collect when a client files an appeal). However, at least where a message is sent electronically and available to a taxpayer’s representatives, it is easier to verify the contents and avoid misunderstandings.
The account portal for businesses has not undergone the same changes. This is regrettable, particularly given the much less forgiving rules applicable to companies or HST registrants in addressing tax issues beyond the filing date. The business site is significantly more challenging to navigate, and while it provides many details about specific issues, it has a few glaring omissions.
In particular, electronic notification of the CRA assessing third parties, such as directors or spouse, for a taxpayers’ debt, would be helpful. At present, taxpayers face a patchwork of numbers for collections and are reliant on telephone conversations, leaving them vulnerable to delays when numbers change and employees leave the Agency or take time off. It can be difficult for a taxpayer assessed this way was to get an accurate picture of their circumstances.
People frequently reach out to our firm when the CRA has garnished accounts or assessed them for several years of unfiled taxes. Where the sole issue is individual income tax, CRA’s site is an essential tool in allowing us to immediately explain our clients’ situation to them and discuss resolving it.
If you need help navigating these matters, contact Kalfa Law to discuss how we may be able to assist you
– James Alvarez, Tax Counsel
© Kalfa Law 2019