CRA Audit Reassessment Appeal 2025

In 2025, CRA’s Audit Reassessment Division is issuing record numbers of tax reassessments based on automated audits, data matching, and AI-generated red flags. Many taxpayers are being hit with inflated reassessments for unverified income, denied expenses, or misunderstood transactions — even when their filings were accurate. CRA often reassesses first and asks questions later, forcing businesses and individuals into unnecessary debt, interest, and penalties. At Mackisen CPA Auditors Montreal, we specialize in defending taxpayers through formal Reassessment Appeals. Our CPA auditors and tax lawyers dissect CRA’s audit findings, expose procedural flaws, and build evidence-based appeals to overturn reassessments entirely. We don’t let CRA’s algorithms rewrite your financial story — we restore truth, fairness, and financial balance.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 152(4): Authorizes CRA to reassess taxpayers but limits its power to three years unless misrepresentation is proven.

• Section 165(1): Grants every taxpayer the right to file a Notice of Objection to dispute a reassessment.

• Section 163(2): Imposes gross negligence penalties, which Mackisen cancels through documented good faith and legal precedent.

• Section 220(3.1): Enables CRA to cancel or reduce penalties and interest under the Taxpayer Relief Program.

• Section 169: Provides the right to appeal to the Tax Court of Canada if CRA refuses to adjust.
  Tax Administration Act (Quebec)
  Revenu Québec applies identical reassessment procedures at the provincial level. Mackisen coordinates both objections to ensure complete defense across jurisdictions.

Key Court Decisions

Bédard v. The Queen (2022): CRA must justify reassessments with verified evidence, not assumption or projection.
Thibault v. The Queen (2022): Audited taxpayers acting with professional advice are not negligent and must be treated fairly.
Guindon v. Canada (2015): Honest reporting errors cannot justify gross negligence penalties.
Jordan v. The Queen (2009): CRA’s reassessments must follow due process or risk being voided.
These rulings confirm that CRA reassessments can be successfully overturned through due diligence, documentation, and legal expertise.

Why CRA Issues Reassessments

CRA’s 2025 audit systems automatically issue reassessments for statistical inconsistencies or industry anomalies. Common triggers include:

• Denied business expenses or personal-use adjustments.

• Misreported investment, rental, or crypto income.

• Home office or vehicle expense claims without full records.

• Late-filed returns or missing slips.

• Differences between CRA’s data and taxpayer filings.
  CRA assumes error — Mackisen proves accuracy and intent.

Mackisen’s Reassessment Appeal Strategy

1. Reassessment Review: Analyze CRA’s audit notes and determine procedural or factual flaws.

2. Evidence Reconstruction: Gather receipts, statements, contracts, and correspondence proving compliance.

3. Formal Objection Filing: File a Notice of Objection to suspend collection and force CRA to re-evaluate.

4. Negotiation and Representation: Engage with CRA Appeals Officers to resolve disputes through evidence and law.

5. Taxpayer Relief Application: File under Section 220(3.1) to cancel penalties and interest arising from reassessment delays.
   Our strategy transforms CRA’s assumptions into documented facts that win your case.

Real Client Experience

A Montreal contractor was reassessed $428,000 for “unreported subcontractor income.” Mackisen proved it was a clerical duplication and CRA cancelled the full reassessment.
A Quebec professional was fined $72,000 for “false deductions.” Mackisen demonstrated documentation compliance and CRA withdrew all penalties.

Common Questions

Can CRA reassess multiple years? Only within three years, except for proven misrepresentation — Mackisen enforces the statute of limitations.
Can CRA charge penalties and interest during appeal? Yes, but Mackisen stops collection once your objection is filed.
Can CRA reassess without audit notice? Yes, but Mackisen can challenge reassessments based on procedural unfairness.
Can CRA reverse a reassessment? Absolutely — Mackisen routinely achieves full reversals with evidence and advocacy.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s most trusted defense firm for CRA reassessments. Our integrated team of CPAs and tax lawyers ensures your case is handled with precision, professionalism, and persistence. We act fast, argue fearlessly, and win consistently — because no taxpayer should pay for CRA’s mistakes. When CRA reassesses you, Mackisen reassesses them.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Reassessment Appeal Consultation. The first meeting is free, and your protection starts immediately.