What Happens If You Don’t See the CRA’s Email?

Why a missed notification could cost you your right to object

The CRA rarely mails letters anymore. If you miss the email telling you correspondence is waiting online, the law may still treat you as having received it and your appeal clock keeps running whether you saw it or not.

For most owner-managed businesses, this isn’t a hypothetical. Audit proposal letters, reassessments, and other CRA correspondence now arrive as a notification in your inbox pointing you to My Business Account, not as a letter in the mail. Miss that one email, and you can lose the right to challenge an assessment before you even know it exists.

How the CRA Delivers Notices Now

Most CRA correspondence, including audit proposal letters and notices of (re)assessment is now posted electronically to a taxpayer’s online account, whether that’s My Business Account for a corporation or My Account for an individual who has registered for electronic delivery. The CRA then sends a short email saying that new correspondence is available to view.

The notice itself is never in the email. You have to log in separately to actually read it.

This catches business owners in a specific way: if your accountant accesses your file through Represent a Client, they are not automatically notified when something new is posted. They only see it if they log in and check. So the assumption that “my accountant will catch it” often doesn’t hold up in practice.

What Is the Deadline to Object to a CRA Assessment?

Once a notice of assessment has been validly issued, a taxpayer has 90 days to file a notice of objection. That deadline is set out in the Income Tax Act and does not bend for oversight or absence.

A late objection can sometimes still be filed through an application for an extension of time but only if that application is made within one year after the original 90-day deadline expires. Miss both windows, and the right to formally object may be gone for good.

What if You Never Actually Saw the CRA’s Email?

The Income Tax Act addresses exactly this scenario. Under the relevant provisions, an electronic notice is treated as sent and received on the day the CRA emails the address it has on file for the taxpayer.

In the reported cases so far, courts have generally sided with the CRA: taxpayers who genuinely didn’t see the notification email, and so never checked their account, have still been treated as having received the notice. This pattern shows up across several Federal Court and Tax Court decisions dealing with missed notifications about excess TFSA contributions, and a parallel rule produces the same result for GST/HST matters.

In practical terms, courts have so far been reluctant to let “I didn’t see the email” undo a missed deadline.

“Presumed” Is Not the Same as “Deemed” and the Difference Matters

There’s an important legal distinction buried in the wording of these provisions. Parliament chose the word “presumed,” not “deemed.”

When the Income Tax Act uses “deemed,” the result is conclusive and cannot be argued around, it creates what the courts call a legal fiction. That’s why a paper notice sent by ordinary mail is treated as received on the date it was mailed, full stop, even if it was genuinely never delivered.

“Presumed” is different. It creates a starting assumption that can be challenged if the actual facts say otherwise.

That distinction suggests that a taxpayer who can demonstrate they truly never received the notification email because of a spam filter, a technical failure, or an email address that changed without being updated with the CRA may have a genuine argument that the clock never started. The wording of the statute supports it, even though the CRA is likely to resist that argument and the courts have not yet fully tested it.

This is a legal nuance worth knowing exists. It is not a plan to rely on after the fact.

What Business Owners Should Do About It

Build this into your regular routine, not your year-end scramble:

•Log into My Business Account periodically, don’t rely on the notification email as your only trigger.

•Confirm the email address the CRA has on file is current, and update it the moment it changes.

•If your accountant has Represent a Client access, ask specifically how often they check for new correspondence, don’t assume they’re automatically alerted.

•Treat CRA account monitoring as part of ongoing financial oversight, the same way you’d treat reviewing your bank statements.

•If you discover a notice you missed, get advice immediately. deadlines are measured from when the CRA says the email was sent, not from when you actually read it.

Frequently Asked Questions

Does the CRA still mail paper notices of assessment?

Less and less. Most businesses and many individuals who use online CRA accounts now receive correspondence electronically, with only an email notification, not the notice itself, landing in their inbox.

How long do I have to object to a CRA assessment?

Generally 90 days from the date the notice of assessment is validly issued. A late objection may sometimes be allowed if an extension request is filed within one year after that 90-day period ends.

What if I missed the CRA’s email and the deadline passed?

Courts have generally required taxpayers to act as though they received the notice once the CRA sent the notification email, even if it was never seen. There is a legal argument, rooted in the difference between “presumed” and “deemed” receipt, that this can be challenged in the right circumstances but it should not be assumed to work, and advice should be sought immediately.

Does my accountant get notified when the CRA posts something new?

Not automatically. An accountant accessing your account through Represent a Client has to log in and check for new correspondence, they don’t receive an email alert the way the taxpayer does.

If you’re not certain how closely your CRA correspondence is being monitored or whether your accountant’s access actually catches what you assume it does, that’s a conversation worth having before a deadline is at risk, not after.