CRA Audit Appeal 2025 — Reverse Unfair Assessments, Cancel Penalties, and Regain Control with Mackisen CPA

In 2025, CRA’s Audit Appeals Division is overloaded with reassessments triggered by automated systems and mass audit campaigns. Many honest taxpayers — individuals, businesses, and professionals — are facing inflated tax bills, denied deductions, and gross negligence penalties based on incomplete or misinterpreted audit evidence. CRA auditors are under pressure to close files fast, often leaving errors uncorrected. At Mackisen CPA Auditors Montreal, we step in when CRA gets it wrong. Our CPA auditors and tax lawyers prepare airtight Audit Appeals to overturn reassessments, eliminate penalties, and restore your financial integrity. We don’t let CRA’s assumptions define your record — we defend truth, documentation, and your right to fairness.

Legal and Regulatory Framework

Income Tax Act (Canada)

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

• Section 169: Provides the right to appeal to the Tax Court of Canada if CRA rejects or delays your objection.

• Section 163(2): Imposes gross negligence penalties that Mackisen challenges through legal precedent and factual proof.

• Section 220(3.1): Allows CRA to cancel or reduce penalties and interest through the Taxpayer Relief Program.
  Tax Administration Act (Quebec)
  Revenu Québec operates a parallel audit and appeals process under similar timeframes. Mackisen coordinates both jurisdictions to ensure unified defense and consistent outcomes.

Key Court Decisions

Bédard v. The Queen (2022): CRA must base reassessments on verified evidence, not estimates or assumptions.
Thibault v. The Queen (2022): Taxpayers who cooperate and provide records cannot be penalized for perceived non-compliance.
Guindon v. Canada (2015): Honest reporting mistakes are not grounds for gross negligence.
Jordan v. The Queen (2009): CRA must respect procedural fairness and allow time for taxpayer representation.
These cases confirm that CRA audit results can be reversed through evidence, legal accuracy, and proper appeal representation.

Why CRA Audit Decisions Go Wrong

CRA’s new digital audit system relies heavily on data algorithms, not professional judgment. Common 2025 triggers include:

• Incorrect expense disallowances.

• Misclassified personal vs. business use.

• Unverified investment or crypto income.

• Disallowed input tax credits or GST/HST claims.

• Penalties assessed without context or warning.
  CRA assumes fault — Mackisen proves compliance.

Mackisen’s Audit Appeal Defense Strategy

1. Audit Review: Examine CRA’s working papers and identify factual or procedural errors.

2. Evidence Reconstruction: Gather receipts, ledgers, contracts, and bank statements to prove correctness.

3. Formal Objection Filing: Submit a Notice of Objection to suspend CRA collections while disputing reassessment.

4. Appeals Representation: Engage CRA Appeals Officers directly with a complete, documented defense package.

5. Penalty & Interest Relief: File under Section 220(3.1) to remove penalties once the appeal is accepted.
   Our strategy transforms CRA’s one-sided audit into a balanced, evidence-based resolution.

Real Client Experience

A Montreal small business was reassessed $418,000 after CRA disallowed subcontractor expenses. Mackisen provided invoices and bank trails — CRA reversed the entire assessment.
A Quebec physician was penalized $92,000 for “improper deductions.” Mackisen demonstrated professional intent and CRA cancelled all penalties.

Common Questions

Can I appeal CRA’s audit results? Yes — Mackisen files formal objections and Tax Court appeals if necessary.
How long do I have to appeal? 90 days from the date of reassessment, or up to one year with an extension.
Can CRA collect while I appeal? Only if no objection is filed — Mackisen ensures all collection is suspended during appeal.
Can penalties be removed if CRA was wrong? Absolutely — Mackisen secures full relief through the Taxpayer Relief Program.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s top defenders against unfair CRA audit decisions. Our integrated team of CPAs and tax lawyers brings decades of combined experience in reversing reassessments, negotiating settlements, and winning appeals. We act fast, document deeply, and argue decisively — because the truth deserves representation. When CRA audits you, Mackisen audits them back.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Audit Appeal Consultation. The first meeting is free, and your protection starts immediately.