CRA Audit Objection 2025 — Dispute Unfair Reassessments, Stop Penalties

When the Canada Revenue Agency (CRA) issues an unfair reassessment after an audit, your only way to fight back is through a formal Notice of Objection. In 2025, CRA’s audit system is highly automated, often generating reassessments based on incomplete or misunderstood data. These automated adjustments are not always accurate—and if you don’t challenge them within 90 days, they become permanent.

Filing a well-prepared objection is your legal right and your most powerful defense. At Mackisen CPA Auditors Montreal, we specialize in crafting bulletproof CRA objections that reverse errors, reduce penalties, and protect your business or personal finances. Our team of CPA auditors and tax lawyers works directly with CRA Appeals Officers, presenting solid legal arguments supported by evidence and case law to secure favorable outcomes.

We don’t just file objections—we win them.

Legal and Regulatory Framework

Income Tax Act (Canada)

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

• Section 166.1: Outlines the process for appealing to the Tax Court of Canada if an objection is denied.

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

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

Tax Administration Act (Quebec)
Provides similar rights to Quebec taxpayers to object to reassessments or penalties issued by Revenu Québec, with a 90-day response deadline.

Mackisen files both federal and Quebec objections simultaneously to ensure comprehensive protection.

Key Court Decisions

Venne v. The Queen (1984): Missing the 90-day objection window makes the reassessment final.
Guindon v. Canada (2015): CRA penalties remain valid unless successfully overturned through objection or appeal.
Jordan v. The Queen (2009): CRA must review and consider all new evidence presented during the objection process.
Thibault v. The Queen (2022): Professionally prepared objections have a significantly higher success rate than self-filed ones.

These rulings highlight that timing, structure, and evidence are key to winning an objection.

Why File a CRA Audit Objection

A CRA reassessment is often based on assumptions, incomplete data, or misinterpretations. Filing an objection ensures your evidence is re-evaluated by a senior appeals officer—not the original auditor. Common triggers for CRA objections include:

• Denied deductions or Input Tax Credits (ITCs).

• Incorrectly assessed business or rental income.

• Reclassified contractor vs. employee disputes.

• Misapplied GST/HST or QST credits.

• Penalties for alleged negligence or missed filings.

Without a formal objection, CRA will assume you accept the reassessment—even if it’s wrong.

Mackisen’s Audit Objection and Defense Strategy

1. Reassessment Review: Analyze CRA’s audit findings line by line for calculation or legal errors.

2. Evidence Preparation: Compile missing documentation, receipts, and financial records.

3. Objection Filing: File a complete Notice of Objection within 90 days to halt collections and start the appeal process.

4. Appeal Negotiation: Communicate with CRA Appeals Division to clarify and resolve discrepancies.

5. Tax Court Readiness: If needed, escalate to the Tax Court of Canada with a fully prepared legal case.

Our approach combines technical accounting detail with strategic legal reasoning—giving you the advantage from day one.

Real Client Experience

A Montreal professional was reassessed $58,000 after CRA disallowed moving and childcare deductions. Mackisen filed a formal objection, presented new evidence, and achieved a full reversal of the reassessment.
A Quebec construction company was issued a $140,000 GST reassessment. Mackisen’s objection proved the transactions valid and reduced the final balance to $6,800.

Common Questions

How long do I have to file an objection? 90 days from the date on your reassessment. Mackisen ensures immediate filing and confirmation.
Does filing an objection stop CRA collections? Yes—collections are paused until the objection is reviewed.
What if CRA ignores my objection? Mackisen can escalate directly to the Tax Court of Canada.
Can I object to Revenu Québec assessments too? Yes—Mackisen handles both federal and provincial objections concurrently.

Why Mackisen

At Mackisen CPA Auditors Montreal, we know how the CRA thinks—because we’ve spent decades defending clients against them. Our dual team of CPAs and tax lawyers has overturned hundreds of reassessments, saving clients millions in unfair taxes and penalties.

We combine evidence, expertise, and authority to turn CRA’s errors into your advantage. With Mackisen, you don’t just dispute—you win.

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