Insights
Oct 24, 2025
Mackisen
CRA Audit for Professionals 2025 — Defend Your Practice, Eliminate Penalties, and Protect Your Reputation
Doctors, lawyers, consultants, engineers, architects, and other professionals are among the top audit targets in 2025. CRA’s new AI-based compliance system automatically analyzes your income, expenses, and corporate filings against peers in your industry. If your numbers fall “outside the expected range,” CRA assumes there’s an error — or worse, tax avoidance. These audits often result in exaggerated reassessments, disallowed business deductions, and serious penalties. But a CRA audit doesn’t have to mean damage to your finances or your name. At Mackisen CPA Auditors Montreal, we defend professionals across Canada with precision, confidentiality, and results. Our CPA auditors and tax lawyers manage every aspect of your defense — from responding to CRA’s audit letter to negotiating a full resolution. We protect your practice, your peace of mind, and your professional integrity.
Legal and Regulatory Framework
Income Tax Act (Canada)
Section 9(1): Governs business income for professional corporations and self-employed professionals.
Section 18(1)(a): Allows deductions for expenses incurred to earn income.
Section 152(4): Permits reassessment but limits CRA’s reach to specified timeframes.
Section 163(2): Imposes gross negligence penalties, which can be disputed or overturned.
Tax Administration Act (Quebec)
Revenu Québec conducts parallel audits for Quebec professionals, especially in incorporated medical, dental, and legal practices. Mackisen ensures both jurisdictions are defended under one unified strategy.
Key Court Decisions
Guindon v. Canada (2015): Penalties must be based on intent, not estimation or assumption.
Venne v. The Queen (1984): CRA cannot rely on reconstructed income without credible proof.
Thibault v. The Queen (2022): Proper documentation and professional representation drastically reduce audit exposure.
Browne v. The Queen (2022): Courts expect CRA to respect procedural fairness in professional audits.
These cases confirm that CRA audits can be won through structure, documentation, and expertise — not fear.
Why CRA Targets Professionals
CRA sees professional income as “audit-rich” because of flexible work structures, high expenses, and corporate tax planning. Common 2025 triggers include:
High expense-to-income ratios.
Inconsistent professional income or billing gaps.
Excessive automobile, travel, or home office deductions.
Medical or legal corporations with retained earnings.
Lifestyle indicators inconsistent with declared income.
CRA assumes risk — Mackisen proves credibility.
Mackisen’s Professional Audit Defense Strategy
File Analysis: Examine CRA’s audit notice, identify red flags, and determine audit scope.
Evidence Preparation: Collect contracts, invoices, and corporate financial records to justify every expense.
Audit Representation: Handle all communication with CRA to ensure accuracy and confidentiality.
Dispute and Negotiation: Challenge CRA’s assumptions using case law, financial logic, and professional standards.
Relief and Resolution: Apply for penalty and interest reduction through the Taxpayer Relief Program.
Our audit strategy is proactive, authoritative, and built to protect your career.
Real Client Experience
A Montreal physician’s corporation was audited for $214,000 in disallowed business expenses. Mackisen provided medical-use documentation and secured a 100% reversal of CRA’s assessment.
A Quebec law firm partner was reassessed for $87,000 in GST/QST discrepancies. Mackisen reconciled client trust records and reduced CRA’s claim by 95%.
Common Questions
Can CRA audit my corporation and personal taxes together? Yes — Mackisen ensures both files are consistent and defensible.
What if I can’t find every receipt? We reconstruct evidence from bank statements and client records to meet CRA standards.
Can CRA review my clients’ files? Only with authorization or a court order — Mackisen protects your client confidentiality.
Can I appeal a professional audit result? Absolutely — we file objections, appeals, and relief applications for full legal protection.
Why Mackisen
At Mackisen CPA Auditors Montreal, we protect professionals who protect others. Whether you’re a doctor, lawyer, engineer, or consultant, our defense blends accounting expertise with legal precision to deliver the strongest results. We act fast, argue hard, and guard your credibility fiercely — because your reputation is worth more than any reassessment. When CRA audits your profession, Mackisen audits their process.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Professional Audit Defense Consultation. The first meeting is free, and your protection begins immediately.
