Estate and trust

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164(6) adjustments

  • 1.  164(6) adjustments

    Posted 09-19-2025 14:12

    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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  • 2.  RE: 164(6) adjustments

    Posted 09-19-2025 17:35

    We aren't seeing a delay in regular estate T3 returns, which were mostly filed in March / April and some in May.  However, anything with complexity is being moved from department to department and is not being processed, and executors are very frustrated. 



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    Jocelyne Dumaresq
    Bishop & Company Chartered Professional Accountants Inc.
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  • 3.  RE: 164(6) adjustments

    Posted 09-22-2025 11:38

    Yes! We have a very outstanding 164(6) adjustment. After a very long time (adjusting a 2022 T1..) the actual tax adjustment was made but the interest on the original tax balance was not reversed. Its over 25K and is holding up the estate distribution. CRA currently says they will address it by May 2026. We put in a complaint (service feedback form) but that has been unaddressed for 3 months now. 



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    Agnete Bay
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  • 4.  RE: 164(6) adjustments

    Posted 10-02-2025 17:21

    Just out of interest, how did you submit the service complaint? I have had fairly prompt replies when submitting the complaint online - although I have not submitted anything recently and processing times may have changed since my last submission. 



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    Maureen Anne Vance
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  • 5.  RE: 164(6) adjustments

    Posted 09-24-2025 11:17

    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
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  • 6.  RE: 164(6) adjustments

    Posted 09-25-2025 00:34

    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.
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  • 7.  RE: 164(6) adjustments

    Posted 09-25-2025 11:21

    Good Morning!

    We have had the recent changes to the authorization program on July 15, 2025 and I've noticed everything go downhill since then. My executor clients can't even get through by phone to follow up. 



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    Candy Davis
    Davis Accounting & Tax Professional Corporation
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  • 8.  RE: 164(6) adjustments

    Posted 10-02-2025 17:31

    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
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  • 9.  RE: 164(6) adjustments

    Posted 10-02-2025 17:50
    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





  • 10.  RE: 164(6) adjustments

    Posted 10-02-2025 18:08

    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
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  • 11.  RE: 164(6) adjustments

    Posted 10-02-2025 18:34
    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





  • 12.  RE: 164(6) adjustments

    Posted 10-02-2025 21:08

    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. 



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    Maureen Anne Vance
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  • 13.  RE: 164(6) adjustments

    Posted 09-25-2025 00:27

    I am still waiting on CRA for a 164(6) adjustment as well. The T1-ADJ was filed with a cheque (cashed in Nov 2024) due to other adjustments that needed to be made as the Executor's brother originally prepared the final return. However, nothing ever showed on the RAC tracker. When I called CRA in Feb 2025, I was told it was marked as a complex adjustment that could take up to 45 weeks.

    When I followed up this month, the agent confirmed the file had been sitting in accounting (where the cheque was processed) and was never sent to adjustments. They've now requested the transfer, and it should appear on the tracker within 3–4 weeks. As of now, nothing is showing, but there are still about two weeks left in that timeframe. They also assured me that it would go into the queue based on the date CRA received the package, not based on the date it arrived in the adjustments department.



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    Erica Minarik
    ELM Chartered Professional Accountant Inc.
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  • 14.  RE: 164(6) adjustments

    Posted 09-25-2025 11:27

    To submit documents to Revenu Canada Deceased tax payer I go into my account, ID rep and submit documents using TX19 discharge description. The cilent's representative authorized me in their ID Rep / My account



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    Claire Bougie
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  • 15.  RE: 164(6) adjustments

    Posted 09-25-2025 12:34
    Edited by Dennis Klander 09-25-2025 13:13

    I just received closure on a 164(6) request that we had been waiting on for 1 year and a half.  We had made a CRA service complaint which seemed to help remind the CRA department that the request was outstanding but, were advised that due to the complexity of these requests the processing takes time. 



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    Dennis Klander
    Vine and Partners LLP
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  • 16.  RE: 164(6) adjustments

    Posted 09-25-2025 14:54

    Yes - I am finding it extremely slow - be sure to mark on the T3 return (if you haven't already) that it is a 164(6) carryback otherwise they will not process the carry back.



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    Trevor Sinclair
    Trevor Sinclair Incorporated
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