CRA Audit Reassessment Appeal 2025 — Challenge CRA Errors, Recover Overpaid Taxes, and Restore Justice with Mackisen CPA Auditors

CRA’s Audit Reassessment Division is issuing record numbers of reassessments based on AI-generated data analysis, often without a full understanding of your business or personal situation. Many taxpayers are being overtaxed because CRA misinterprets income, disallows valid deductions, or applies penalties automatically. These reassessments can devastate businesses and individuals if not appealed within the strict 90-day deadline. At Mackisen CPA Auditors Montreal, we specialize in reversing CRA audit reassessments. Our CPA auditors and tax lawyers analyze every detail, identify errors, and build powerful legal and financial defenses to overturn unjust tax bills. We don’t let CRA’s algorithms decide your financial fate — we restore fairness through facts, law, and persistence.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 152(4): Permits CRA to reassess a taxpayer within three years unless fraud or misrepresentation is proven. Section 165(1): Grants the taxpayer the right to file a Notice of Objection to dispute the reassessment. Section 169: Provides appeal rights to the Tax Court of Canada when CRA refuses correction. Section 163(2): Allows penalties only when intent or gross negligence is proven — Mackisen ensures CRA meets this burden. Section 220(3.1): Enables CRA to cancel or reduce penalties and interest through the Taxpayer Relief Program.
Tax Administration Act (Quebec) Revenu Québec follows a parallel reassessment and appeal structure. Mackisen handles both levels simultaneously to ensure full and coordinated defense.

Key Court Decisions

Bédard v. The Queen (2022): CRA must provide factual evidence, not assumptions, to justify reassessment. Thibault v. The Queen (2022): Taxpayers with documentation and good faith cannot be penalized for CRA’s interpretation errors. Guindon v. Canada (2015): Honest mistakes are not grounds for gross negligence penalties. Jordan v. The Queen (2009): CRA must uphold procedural fairness and provide reasonable time for defense. These rulings confirm that reassessments based on assumption or incomplete evidence cannot stand when properly challenged.

Why CRA Reassessments Are Increasing

CRA’s 2025 audit programs rely heavily on algorithms that identify statistical discrepancies without human review. Common triggers include home office deductions, business income fluctuations, management fees, or unreported investment income. CRA assumes non-compliance — Mackisen proves compliance through evidence, accuracy, and context.

Mackisen’s Reassessment Appeal Strategy

1. File Analysis: Review CRA’s reassessment letter and audit notes to uncover legal and factual weaknesses. 2. Evidence Reconstruction: Compile all relevant records, receipts, and professional reports to support your position. 3. Notice of Objection Filing: Submit within 90 days to suspend collection and begin the formal appeal. 4. Negotiation and Advocacy: Present evidence and legal arguments directly to CRA’s Appeals Division. 5. Penalty and Interest Relief: File under Section 220(3.1) for full or partial cancellation of financial penalties. Mackisen’s structured method transforms CRA’s errors into opportunities for correction and relief.

Real Client Experience

A Montreal engineering firm was reassessed $276,000 for “unreported management fees.” Mackisen filed an objection, presented evidence, and CRA reversed the entire assessment. A Quebec contractor faced $94,000 in penalties for “inconsistent deductions.” Mackisen demonstrated valid business documentation and CRA cancelled all charges.

Common Questions

Can I appeal a CRA reassessment after the 90-day deadline? Yes, Mackisen can file for an extension under Section 166.1 if justified. Can CRA reassess multiple years? Only within the statute of limitations unless fraud is proven. Can CRA cancel penalties after appeal? Absolutely, through the Taxpayer Relief Program. What if CRA refuses my appeal? Mackisen can escalate your case to the Tax Court of Canada for independent review.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leading specialists in CRA reassessment appeals. Our team of CPAs and tax lawyers combines technical expertise with legal precision to protect your rights and recover overpaid taxes. We act strategically, advocate relentlessly, and win consistently — because accuracy should never be punished. When CRA reassesses, Mackisen resets the truth. Call Mackisen CPA Auditors Montreal today for your 2025 Reassessment Appeal Consultation. The first meeting is free, and your protection starts immediately.