Legal guidance when the CRA questions your CERB or COVID benefit eligibility

Free 15-Minute Consultation for Tax Law Disputes

If you have received a CRA letter about CERB, CRB, or other COVID benefit repayments, you are not alone. Many individuals and business owners across Toronto and Ontario are now facing reassessments, repayment demands, penalties, or interest related to pandemic benefits.

Get started with a free 15-minute consultation!

Facing a CERB or COVID Benefit Reassessment

CRA reviews of CERB, CRB, and other pandemic benefits often involve strict eligibility interpretations. Many reassessments are issued years after payments were received, creating financial stress and uncertainty.

Clients come to us after receiving:

  • CRA letters demanding CERB repayment
  • Notices of Reassessment or Determination
  • Requests for proof of income or employment status
  • Findings of ineligibility based on technica criteria
  • Penalties or interest added to repayment amounts

In some cases, the CRA applies narrow readings of income thresholds or employment interruptions. In others, documentation issues trigger reassessment even where eligibility existed.

How We Help With CERB Reassessments

Reviewing the CRA Decision

We begin by reviewing the CRA’s position and the reasons for reassessment. This includes:

  • Assessing eligibility under the applicable benefit rules
  • Reviewing income calculations and reporting periods
  • Identifying factual or legal errors
  • Clarifying what evidence the CRA relied upon

Many reassessments involve misunderstandings that can be challenged when properly addressed.

How We Help With CERB Reassessments

Reviewing the CRA Decision

We begin by reviewing the CRA’s position and the reasons for reassessment. This includes:

  • Assessing eligibility under the applicable benefit rules
  • Reviewing income calculations and reporting periods
  • Identifying factual or legal errors
  • Clarifying what evidence the CRA relied upon

Many reassessments involve misunderstandings that can be challenged when properly addressed.

Preparing a CRA Objection

If a reassessment has been issued, strict deadlines apply.

We assist by:

  • Preparing and filing a Notice of Objection
  • Presenting eligibility arguments clearly and accurately
  • Organizing supporting documents and explanations
  • Challenging penalties and interest where appropriate

A well-prepared objection improves the chance of resolving the matter without court proceedings.

Our Tax Lawyers

Graeme Oddy is a partner with Devry Smith Frank LLP in our tax litigation department.

With years of litigation experience, Graeme is able to provide practical, client-focused advice and guide clients through high-stakes tax disputes with clarity and care.

  • Focused on practical outcomes that protect financial rights

  • Skilled in courtroom advocacy

  • Effective at organizing accounting evidence, third-party documentation, and challenging reassessments

Alex Shchukin is an associate with Devry Smith Frank LLP in our litigation department.

His work includes advising on litigation prospects, drafting settlement proposals, and assisting with strategy in a wide range of files.

  • Skilled at building persuasive objection records and appeal strategies

  • Clear and direct communication

  • Quick to act when urgent matters arise

Document Review Included

To make your consultation as productive as possible, our tax litigation lawyers will review the key documents you provide in advance, such as CRA audit letters, CERB reassessments, notices of objection, or appeal materials, so we can give you focused and accurate guidance from the start.

Speak to a Tax Law Lawyer Today

Our experienced team of tax litigation lawyers guides clients through the technical and procedural challenges of dealing with the CRA while pursuing outcomes that minimize risk and cost.