CRA Audit Appeal 2025 — Overturn Unfair Reassessments and Protect Your Rights with Mackisen CPA Auditors Montreal

A CRA Audit Appeal is your second chance to fight back—and often, your last line of defense before costly penalties become permanent. When the Canada Revenue Agency (CRA) reassesses your return after an audit, you have 90 days to appeal the decision through a formal process. In 2025, CRA’s appeal system has become faster, more automated, and more complex, using AI and data analytics to filter which objections move forward. That means poorly prepared or incomplete appeals are dismissed instantly—while well-documented, professionally argued ones can save you thousands.

At Mackisen CPA Auditors Montreal, we turn CRA disputes into success stories. Our CPA auditors and tax lawyers combine legal precision with accounting expertise to dismantle weak CRA audit findings, prove compliance, and secure reversals before the case escalates to court. We manage everything—from objection filing to negotiation—ensuring your appeal is built on facts, law, and strategy.

When CRA audits your books, we audit their judgment.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 165(1): Allows taxpayers to file a Notice of Objection within 90 days of reassessment.

• Section 166.1: Grants the right to appeal to the Tax Court of Canada if CRA denies or ignores your objection.

• Section 161(1): Applies daily interest on disputed balances until resolved.

• Section 220(3.1): Permits penalty and interest relief under the Taxpayer Relief Program.

Tax Administration Act (Quebec)
Revenu Québec has a similar audit and appeal system, where taxpayers can file an objection to contest provincial reassessments, ensuring parallel defense for both federal and provincial files.

Mackisen handles CRA and Revenu Québec appeals simultaneously, keeping your defense unified and consistent across jurisdictions.

Key Court Decisions

Venne v. The Queen (1984): Appeals succeed when taxpayers present clear, organized evidence refuting CRA’s assumptions.
Guindon v. Canada (2015): CRA penalties remain enforceable unless challenged under proper appeal procedures.
Thibault v. The Queen (2022): Courts give preference to taxpayers who act quickly and provide professional submissions.
Jordan v. The Queen (2009): CRA must review all evidence submitted during the appeal process—not just the initial audit file.

These decisions make one thing clear: winning an audit appeal requires action, accuracy, and expertise.

Why CRA Audit Appeals Matter

A CRA reassessment can threaten your cash flow, reputation, and financial credibility. Filing a proper appeal protects you from collection actions, freezes enforcement, and gives you a fair chance to challenge errors.

Common 2025 audit appeal triggers include:

• Disallowed business or rental expenses.

• Incorrect GST/HST or QST adjustments.

• Misinterpreted personal-use expenses (vehicles, home office).

• Denied Input Tax Credits (ITCs).

• CRA calculation or data-matching errors.

If ignored, these errors can grow into years of accumulated tax, interest, and penalties—destroying your business’s financial health.

Mackisen’s CRA Audit Appeal and Defense Strategy

1. Reassessment Review: Examine CRA’s audit file, findings, and evidence for calculation or procedural errors.

2. Document Reconstruction: Gather missing invoices, contracts, and proof of deductions or credits.

3. Legal Objection Filing: File a professional Notice of Objection within 90 days to suspend CRA enforcement.

4. Negotiation and Representation: Communicate with CRA’s Appeals Division to correct or settle the dispute.

5. Tax Court Escalation (if needed): Prepare full legal submissions if CRA refuses to reconsider.

Our strategy builds a strong factual foundation to overturn weak CRA claims and secure full or partial relief.

Real Client Experience

A Montreal retailer was reassessed $121,000 after CRA denied inventory deductions. Mackisen reconstructed records, filed an objection, and achieved a full reversal within 11 weeks.
A consulting firm was penalized for “unsubstantiated GST credits.” Mackisen’s appeal proved every claim legitimate, saving the client over $54,000 in taxes and interest.

Common Questions

How long do I have to file a CRA appeal? You have 90 days from the reassessment date—but Mackisen can request an extension of up to one year if justified.
Will CRA stop collections while I appeal? Yes—collections are frozen once an objection is filed.
Can I appeal both CRA and Revenu Québec audits? Yes. Mackisen manages both simultaneously to ensure consistent outcomes.
Do I need a lawyer for a CRA appeal? Not always—but Mackisen’s team includes both CPAs and tax lawyers for maximum protection.

Why Mackisen

At Mackisen CPA Auditors Montreal, we don’t just challenge CRA—we outthink them. Our success comes from combining audit expertise, deep tax law knowledge, and a relentless commitment to client protection. Whether you’re appealing a reassessment, fighting penalties, or correcting CRA errors, we bring the strategy and structure that wins.

We act fast, build smart, and defend fearlessly—because when the CRA gets it wrong, Mackisen makes it right.

Call Mackisen CPA Auditors Montreal today for your 2025 CRA Audit Appeal Consultation. The first meeting is free, and your protection begins immediately.