CRA Audit Objection 2025 — Stop Collections, Reverse CRA Errors, and Win Your Case with Mackisen CPA

In 2025, CRA’s Audit Objection and Appeals Process has become more complex than ever. Thousands of Canadian businesses and individuals are being reassessed unfairly, and most don’t realize they have only 90 days to file a formal objection. Missing that deadline can cost you your refund, increase penalties, and leave CRA free to collect disputed taxes. At Mackisen CPA Auditors Montreal, we represent taxpayers in every stage of CRA objection and appeal. Our CPA auditors and tax lawyers prepare detailed legal submissions, challenge CRA’s audit findings, and stop collections immediately. We don’t just argue — we prove. Our mission is simple: overturn CRA’s mistakes and protect your rights under the law.

Legal and Regulatory Framework

Income Tax Act (Canada)

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

• Section 165(3): Requires CRA’s Appeals Division to review objections independently from the original auditor.

• Section 220(3.1): Authorizes penalty and interest cancellation through the Taxpayer Relief Program.

• Section 152(4): Defines reassessment limits and protects taxpayers from arbitrary reopenings.
  Excise Tax Act (Canada)

• Section 301: Governs GST/HST objections and appeals procedures for businesses.
  Tax Administration Act (Quebec)
  Revenu Québec enforces parallel objection rights under provincial law. Mackisen ensures both federal and provincial objections are filed simultaneously for coordinated defense.

Key Court Decisions

Bédard v. The Queen (2022): CRA Appeals must evaluate objections independently, not rely on the auditor’s conclusions.
Thibault v. The Queen (2022): Objections supported by documentation and expert reports carry more weight than CRA assumptions.
Guindon v. Canada (2015): Honest taxpayers cannot be penalized for minor or administrative errors.
Venne v. The Queen (1984): CRA must justify reassessments — taxpayers are not presumed guilty.
These rulings confirm that a well-prepared objection can reverse CRA reassessments and stop financial harm.

Why CRA Reassessments Require Objections

CRA reassessments often stem from audit errors, missing context, or algorithmic flagging. Common 2025 triggers include:

• Denied business expense deductions.

• Disallowed GST/HST Input Tax Credits.

• Incorrect income classification or capital gain treatment.

• Payroll and source deduction disputes.

• Double taxation on intercompany or shareholder transactions.
  CRA assumes non-compliance — Mackisen proves accuracy.

Mackisen’s Audit Objection Strategy

1. Case Analysis: Review CRA’s reassessment letter and identify all errors in law or fact.

2. Evidence Compilation: Gather receipts, contracts, and financial statements to rebuild the case with precision.

3. Legal Submission: File a comprehensive Notice of Objection supported by statutory and case law references.

4. Appeals Negotiation: Engage directly with CRA Appeals Officers to resolve disputes before court involvement.

5. Penalty & Interest Relief: Apply under Section 220(3.1) for cancellation once errors are acknowledged.
   Our strategy ensures your case is presented with professionalism, authority, and irrefutable documentation.

Real Client Experience

A Montreal manufacturer was reassessed $312,000 for “improper deductions.” Mackisen filed an objection and CRA reversed the reassessment within eight weeks.
A Quebec medical professional faced $146,000 in GST/HST penalties. Mackisen filed simultaneous objections federally and provincially and secured full penalty relief.

Common Questions

How long do I have to file an objection? You have 90 days from the date of reassessment — Mackisen ensures timely, complete submissions.
Does filing an objection stop collections? Yes — CRA cannot collect while an objection is under review.
Can I file an objection after the deadline? Yes, under specific conditions — Mackisen prepares late applications with legal justification.
Do objections really work? Absolutely — most reassessments are reduced or cancelled when properly defended.

Why Mackisen

At Mackisen CPA Auditors Montreal, we specialize in reversing unfair CRA decisions. Our integrated team of CPAs and tax lawyers builds airtight objections that win — fast. We act within deadlines, argue with authority, and deliver relief that protects your financial future. When CRA reassesses your taxes, Mackisen reassesses their conclusions.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Objection and Appeals Consultation. The first meeting is free, and your protection starts immediately.