This self-paced certificate program includes 12.5 hours of learning, comprising 11 hours of on-demand recordings and 1.5 hours of Q&A content. Delivered through five modules and 29 recorded lessons, the course allows participants to learn at their own pace while reinforcing key taxation concepts through self-guided practice questions with detailed answers and explanations. No formal prerequisites are required, although a working knowledge of Canadian income tax compliance is recommended.

A CRA reassessment is not the end of the story. It is the start of a process with strict deadlines, specific statutory powers on both sides, and real opportunities for a well-prepared practitioner to change the outcome. Knowing when a year is truly statute barred, what an auditor can and cannot demand, who has to prove a penalty, and how to file an objection that holds up on appeal can be worth significant tax, interest and penalties to your client.

Assessed, Not Final is an on-demand certificate that takes you through the full life of a CRA dispute. You will start with the assessment and reassessment rules in section 152, move through the conduct of a CRA audit and the CRA’s information gathering powers, examine the penalty provisions that apply to taxpayers and to advisers, and then work through objections, appeals to the Tax Court of Canada, taxpayer relief and the current Voluntary Disclosures Program. The final module is a practical workshop: a complete international voluntary disclosure package, prepared form by form.

This is not a survey of the legislation. Each topic is taught through the Income Tax Act, the CRA’s own published views and Income Tax Audit Manual guidance, and the court decisions that shape how the rules are applied in practice. One realistic client file, an Ontario owner managed manufacturing group with a U.S. subsidiary, runs through the first four modules, so you see how assessment periods, audit powers, penalties and objections interact on a single engagement. Every module ends with a list of the ten points where this work most often goes wrong on real files.

Because the certificate is fully on demand, you can study at your own pace, pause to work through the examples, and return to specific topics whenever a client file calls for them. To test and reinforce your learning, each module includes review questions, and a knowledge check of 15 questions covers the full certificate. Complete answers and explanations are provided so you can check your understanding on your own.

You will leave with the technical depth and the practical judgment to manage CRA audits with confidence, protect your clients’ rights, and recover value through objections, relief requests and voluntary disclosures.

Upon completion of this certificate, you will be able to:

• Determine the normal, extended and special reassessment periods under section 152, identify when a year is statute barred, and build a reassessment timeline for a client group.
• Evaluate whether the CRA can reopen a statute barred year for misrepresentation, apply the burden of proof correctly, and use subsection 152(4.01) to confine a reassessment to what the year is actually open for.
• Advise clients on whether to sign a waiver, and how to file or revoke one.
• Manage a CRA audit from the contact letter through the proposal letter and closing letter, using the CRA’s own Audit Manual instructions to your client’s advantage.
• Respond to inspections, requirements for information, foreign based information requirements and compliance orders, including the powers rewritten in 2022, and track proposed changes to the CRA’s audit powers.
• Protect privileged communications, recognize the limits of privilege for an accountant’s file, and handle tax accrual working papers.
• Assess exposure to the repeated failure to report income penalty, the gross negligence penalty and the third party penalties on advisers, and build due diligence and burden of proof arguments against them.
• File objections that meet the statutory requirements, including the special rules for large corporations, and manage extensions of time, Tax Court appeals and settlements.
• Prepare effective requests for taxpayer relief of penalties and interest, and for late, amended or revoked elections.
• Determine eligibility for the current Voluntary Disclosures Program, distinguish prompted from unprompted applications, and estimate the relief available.
• Complete the T1134, T1135 and T106, prepare a treaty based return with Schedules 91 and 97, and assemble a complete voluntary disclosure package with Form RC199.