CRA Audit Defense 2025 — Protect Your Business, Stop Reassessments, and Win Against CRA with Mackisen CPA

In 2025, CRA’s Audit and Enforcement Division has intensified its focus on small businesses, professionals, and corporations. Using advanced AI analytics, CRA now cross-matches income tax, payroll, and GST filings to identify “inconsistencies.” Even compliant businesses are being audited for minor discrepancies in invoices or expense claims, resulting in inflated reassessments and unnecessary penalties. At Mackisen CPA Auditors Montreal, we defend taxpayers against CRA’s most aggressive audits. Our CPA auditors and tax lawyers step in immediately to manage all CRA communications, prepare strong responses, and dismantle inaccurate findings before they become costly. We don’t react — we take control. When CRA audits your business, Mackisen protects it from start to finish.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 231.1: Gives CRA authority to request records, but it must be exercised reasonably and within limits.

• Section 18(1)(a): Allows deduction of business expenses incurred to earn income.

• Section 67: Requires all deductions to be “reasonable in the circumstances.”

• Section 163(2): Imposes gross negligence penalties that Mackisen can remove through defense and evidence.

• Section 220(3.1): Enables CRA to cancel or reduce penalties and interest under the Taxpayer Relief Program.
  Tax Administration Act (Quebec)
  Revenu Québec performs concurrent audits for QST, payroll, and income tax compliance. Mackisen coordinates both agencies for one unified defense strategy.

Key Court Decisions

Bédard v. The Queen (2022): CRA must rely on verifiable records, not assumptions, during audits.
Thibault v. The Queen (2022): Proper documentation and professional oversight protect taxpayers from penalties.
Guindon v. Canada (2015): Penalties cannot apply to good-faith or administrative errors.
Venne v. The Queen (1984): CRA’s assessments must be based on fact, not estimation or conjecture.
These rulings confirm that CRA audit results can be overturned with professional representation and documented compliance.

Why CRA Targets Businesses for Audit

CRA uses data analytics and algorithms to flag accounts based on perceived risk. Common 2025 audit triggers include:

• High or recurring expense claims.

• Year-to-year income fluctuations.

• Cash-heavy operations or mixed personal/business expenses.

• Employee vs. contractor classification issues.

• Unfiled returns or delayed GST/HST remittances.
  CRA assumes error — Mackisen proves legitimacy.

Mackisen’s CRA Audit Defense Strategy

1. Risk Analysis: Review CRA’s audit letter, target areas, and supporting data.

2. Evidence Preparation: Organize all accounting, banking, and transactional documentation.

3. Representation: Communicate directly with CRA auditors on your behalf to prevent misstatements.

4. Objection and Negotiation: File a Notice of Objection if reassessed, supported by legal reasoning and financial evidence.

5. Penalty Relief: Apply under Section 220(3.1) to cancel penalties and interest once compliance is proven.
   Our approach combines expert accounting, legal advocacy, and strategic communication to protect your bottom line.

Real Client Experience

A Montreal retail chain was audited for “inflated expenses” and reassessed $321,000. Mackisen provided receipts and CRA reversed 100% of the audit.
A Quebec tech firm was penalized for “improper GST claims.” Mackisen reconstructed their books and secured full penalty cancellation.

Common Questions

Can CRA audit multiple years? Yes — typically three years, longer for alleged misrepresentation. Mackisen enforces legal reassessment limits.
Can CRA seize bank accounts during an audit? Yes, if reassessment becomes final — Mackisen stops it with timely objection and representation.
Do I need to meet CRA in person? No — Mackisen handles all auditor communication and documentation.
Can penalties be removed after audit? Yes — Mackisen applies for full relief under Section 220(3.1).

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s front-line defense against CRA audits. Our firm integrates accounting precision, legal intelligence, and negotiation expertise to protect you from unnecessary reassessments. We act immediately, prepare meticulously, and fight relentlessly — because every dollar and reputation matter. When CRA audits your company, Mackisen audits their process.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Audit Defense Consultation. The first meeting is free, and your protection starts immediately.