CRA Audit Reassessment 2025 — Reverse Penalties, Stop Interest, and Win Back Your Refund

Receiving a CRA Audit Reassessment can feel like the final blow — but it’s actually your most critical opportunity to fight back. In 2025, the CRA’s AI-enhanced audit systems reassess millions of taxpayers and businesses based on algorithmic “risk profiles.” These reassessments often exaggerate income, deny legitimate deductions, or misinterpret data from audits. Many Canadians end up owing thousands they don’t truly owe.

A reassessment isn’t final — it’s a claim. And claims can be challenged. At Mackisen CPA Auditors Montreal, we specialize in overturning CRA audit reassessments through detailed evidence, legal arguments, and negotiation. Whether you’re facing personal, corporate, or GST/HST reassessments, our team of CPA auditors and tax lawyers will dismantle CRA’s case point-by-point, defend your records, and restore your financial standing.

When CRA reassesses your taxes, Mackisen reassesses their mistakes.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 152(4): Authorizes CRA to reassess prior years’ returns but limits how far back they can go.

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

• Section 161(1): Applies daily compounded interest on any balance owing.

• Section 163(2): Allows gross negligence penalties for omitted income or misreported deductions.

Tax Administration Act (Quebec)
Revenu Québec has equal power to reassess, often mirroring CRA’s actions. Mackisen ensures both assessments are handled together to avoid overlap or double taxation.

Key Court Decisions

Venne v. The Queen (1984): CRA reassessments can be overturned if taxpayers produce sufficient evidence of accuracy.
Guindon v. Canada (2015): CRA penalties are valid until proven unreasonable through formal objection or appeal.
Jordan v. The Queen (2009): CRA must consider all documentation presented before confirming reassessment.
Thibault v. The Queen (2022): Courts favor taxpayers who act quickly and present professionally structured defenses.

These decisions prove one thing — CRA’s word is not law unless you stay silent.

Why CRA Issues Audit Reassessments

CRA audit reassessments often stem from data discrepancies, incomplete records, or misunderstood transactions. Common triggers include:

• Unreported income or missing T4/T5 slips.

• Denied business or rental expenses.

• Disallowed medical, charitable, or moving deductions.

• Misinterpreted GST/HST claims.

• CRA system errors or data-matching inaccuracies.

The problem? CRA reassessments are often based on assumptions, not facts — and assumptions can be disproven.

Mackisen’s CRA Audit Reassessment Defense Strategy

1. Audit File Analysis: Examine CRA’s reassessment letter, calculations, and source data for inconsistencies.

2. Evidence Reconstruction: Gather invoices, bank statements, and supporting documentation CRA may have overlooked.

3. Legal Objection Filing: Submit a detailed Notice of Objection within 90 days to freeze enforcement and start the appeal process.

4. Negotiation with CRA Appeals: Present evidence, legal citations, and financial analysis to challenge the reassessment.

5. Settlement or Appeal: Pursue reversal, reduction, or full cancellation through negotiation or Tax Court if necessary.

Our goal is simple: turn CRA’s reassessment into your recovery.

Real Client Experience

A Montreal business owner was reassessed $84,000 after CRA denied business expenses. Mackisen reconstructed records, proved all deductions legitimate, and achieved a complete reversal within 10 weeks.
A Quebec consultant faced $29,000 in GST reassessments from duplicate transactions. Mackisen demonstrated CRA’s system error — the reassessment was fully withdrawn.

Common Questions

Can CRA reassess without notice? CRA must issue a formal Notice of Reassessment before collection begins. Mackisen can challenge it immediately.
How long does CRA have to reassess? Normally 3 years, but up to 10 if CRA alleges negligence or misrepresentation.
Do I have to pay while disputing? No. Filing a formal objection suspends collections during the process.
What if CRA already took my refund? Mackisen can recover overpayments through audit correction and appeal.

Why Mackisen

At Mackisen CPA Auditors Montreal, we treat every reassessment as a battle of facts — and we never lose on assumptions. Our team combines the sharp analysis of CPAs with the strategic precision of tax lawyers to challenge CRA’s conclusions and restore fairness.

We protect your money, your record, and your confidence — because one reassessment doesn’t define your compliance, it tests it.

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