Sorry - I may have misunderstood your message. I now realize that you were indicating that the daughter had obtained a RepID and had accessed her mother's account via Represent a Client. So did you provide the will, death certificate and RC411 in order for her to be established as the legal representative? If this was done in September, then CRA worked reasonably quickly.
And I agree - that if the legal representative can get access to the deceased's account, then they can authorize a representative. But this does still involve providing CRA with the documents and waiting for them to process them. And the legal representative has to set up a RepID and go online - which not everyone is comfortable doing (especially if the legal rep is a senior that is not comfortable with technology).
But I am still disappointed that the CRA rep was not able to point you to the correct option in Submit Documents to upload the will, etc. I will mention this to CRA - they really need to do a better job educating their agents.
Original Message:
Sent: 10-02-2025 18:34
From: Claire Bougie
Subject: 164(6) adjustments
Hi Maureen Anne,
If Revenu Canada received confirmation with the will of the name of the executor and the executor as an ID Rep to represent the deceased person the ID Rep has full access to the deceased tax account including the tax slips and can give the cpa access.
Best regards,
| Claire Bougie CPA pour l'avancement |
| cell.: 514-912-4261 | | | |
| | | |
Original Message:
Sent: 10/2/2025 6:08:00 PM
From: Maureen Anne Vance
Subject: RE: 164(6) adjustments
It is disappointing (but not surprising) to hear that the CRA agent did not know about the option to upload the death certificate and will. The option is called "Update to owner/legal representative/executor/trustee".
It sounds like the daughter accessed her mother's account after her death - which she is not supposed to do (even though we know it happens). If CRA had known the taxpayer was deceased (e.g. if they had received notification from Service Canada due to the application for the death benefit) then that would not have been possible as CRA would restrict access to My Account.
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Maureen Anne Vance
Original Message:
Sent: 10-02-2025 17:50
From: Claire Bougie
Subject: 164(6) adjustments
The deceased person's daughter created an ID Rep in her mother's My Account Revenu Canada there she gave me authorization to represent her mother and access to all the tax slips and information concerning the deceased person.
I uploaded the death certificat, will and Form RC411 this sept. . No specific description existed for these uploads but CRA told me using the Discharge TX19 description would be ok. I worked.
| Claire Bougie CPA pour l'avancement |
| cell.: 514-912-4261 | | | |
| | | |
Original Message:
Sent: 10/2/2025 5:31:00 PM
From: Maureen Anne Vance
Subject: RE: 164(6) adjustments
CRA has changed the options for getting authorization for a deceased taxpayer several times over the past few years. You used to be able to EFILE the request for authorization which would be given a conditional acceptance and then CRA would automatically grant authorization once they had processed the documents to update the legal representative (e.g. will and death certificate). If you uploaded the documents you could get authorization in about 10 business days. But then they started requiring that the legal rep be updated before they would accept the authorization request.
But I would not recommend sending paper documents to CRA - it is much faster to upload them via Submit Documents. Unfortunately I have heard from colleagues that some CRA agents may still be instructing preparers to mail/courier the documents.
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Maureen Anne Vance
Original Message:
Sent: 09-25-2025 00:34
From: Erica Minarik
Subject: 164(6) adjustments
Hi Candy,
I am also having major issues with registering legal rep's for deceased taxpayers so I can get access as an authorized rep. I thought something changed because I have been sending in the same package for many years and only started having trouble this year. I had one where both the Executrix and myself had to do a conference call with CRA to get access. I asked the CRA agent if there was an issue with what I had sent in that caused the problem/delay because I want to fix whatever I am doing. She said that she doesn't see any issue with what I sent in and she can't tell why it did not get approved in the first place.
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Erica Minarik
ELM Chartered Professional Accountant Inc.
Original Message:
Sent: 09-24-2025 11:17
From: Candy Davis
Subject: 164(6) adjustments
I am certainly seeing those taking an extremely long time, in fact, any T1 Adjustment that requires manual overview seems to get stuck on "pending". I have now become the thorn that will file the service complaint for every delayed file. It seems to get them addressed faster. In every case- they had just not been assigned to anyone or had been but the file was never addressed.
Furthermore, the processing of registering legal representatives to even be able to register the authorized rep seems to now be at a standstill. I could pull my hair out. Feel free to use the service complaints- they seem to be our only course of action considering calling in for updates results in no answers.
I did notice that even the Service Complaint Department is now delayed and is now only addressing matters from June 2025. I used to get a response within a week so... it's bad all around, sadly.
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Candy Davis
Davis Accounting & Tax
Original Message:
Sent: 09-19-2025 14:12
From: William George Wray
Subject: 164(6) adjustments
Have a number of requests into Canada Revenue Agency that went in by paper (registered mail or UPS when Canada Post labour dispute was ongoing), these requests are at least 6 - 11 months old. Requests show on progress tracker on Represent A Client but do not seem to be progressing. Lately have been sending these adjustment in by T1 refile feature. Just wondering if anyone else is having this type of delay as estate trustees are getting frustrated?
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William George Wray
Harvest Gold Financial
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