The growing technical complexity of the Income Tax Act, which makes it harder for taxpayers to understand the rules and for the agency to apply them correctly, is likely one reason behind the rise in objections, Mr. O’Riordan said.

But the soaring number of objections could also signal that Ottawa has put increased emphasis on tax compliance in recent years without proportionally increasing resources to help taxpayers comply with the tax code and to review disputes, he said.

https://www.theglobeandmail.com/investing/personal-finance/article-canada-revenue-agency-objections-taxpayers/