CRA Audit Representation 2025 — Protect Your Rights, Control the Process, and Win Against CRA with Mackisen CPA Auditors

CRA’s audit activity has reached an all-time high, with advanced algorithms flagging millions of returns for review. CRA is now auditing individuals, professionals, and corporations based on spending patterns, bank activity, and digital records. Many taxpayers make the mistake of facing CRA alone — a decision that can lead to overpayment, lost deductions, and unnecessary penalties. At Mackisen CPA Auditors Montreal, we represent you directly before CRA, manage all communication, and ensure that every number, statement, and document is defended professionally. Our CPA auditors and tax lawyers take control of the audit, protect your rights, and prevent CRA from overstepping. We don’t let the system intimidate you — we make it work in your favor.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 231.1(1): Grants CRA the authority to inspect and audit records but requires reasonable cause. Section 231.2(1): Authorizes CRA to request information or documents but limits intrusion without justification. Section 163(2): Covers penalties for gross negligence, which Mackisen prevents or eliminates through representation. Section 152(4): Defines CRA’s reassessment period and limits their ability to revisit prior years without valid cause. Section 220(3.1): Allows CRA to cancel or reduce penalties under the Taxpayer Relief Program when reasonable error is proven.
Tax Administration Act (Quebec) Revenu Québec conducts similar audits, often sharing data with CRA. Mackisen coordinates both levels to ensure consistency, minimize duplication, and prevent overreach.

Key Court Decisions

Bédard v. The Queen (2022): CRA must justify audit requests and respect taxpayer rights during examinations. Thibault v. The Queen (2022): Auditors cannot make arbitrary assumptions without documented proof. Guindon v. Canada (2015): Penalties cannot be applied when taxpayers act in good faith. Jordan v. The Queen (2009): CRA must maintain fairness, proportionality, and procedural integrity during audits. These rulings confirm that representation protects taxpayers from errors and unfair assumptions.

Why CRA Audits Increase Every Year

CRA’s digital enforcement systems automatically detect irregularities in expenses, income, and investment reporting. Common 2025 triggers include mismatched T-slips, large expense claims, repeated losses, or unreported foreign assets. CRA assumes non-compliance — Mackisen proves accuracy and compliance with precision.

Mackisen’s Audit Representation Strategy

1. File Assessment: Review CRA’s audit notice and define the scope and objectives. 2. Data Preparation: Organize tax returns, receipts, and documentation for accurate and consistent defense. 3. Direct Representation: Communicate exclusively with CRA on your behalf to control the audit narrative. 4. Legal Defense: Identify procedural violations, unverified assumptions, or overreaches in CRA’s audit approach. 5. Penalty and Interest Relief: File under Section 220(3.1) for cancellation of penalties resulting from audit mismanagement. Mackisen ensures you never face CRA alone — every interaction is strategic, documented, and secure.

Real Client Experience

A Montreal IT consultant was audited for three years of income and expenses. Mackisen represented the client, corrected CRA’s errors, and reduced taxes owed by 90 percent. A Quebec logistics firm faced a $284,000 reassessment for vehicle expenses. Mackisen negotiated directly with CRA and secured full withdrawal of the audit findings.

Common Questions

Can CRA audit my personal and business accounts together? Yes, but Mackisen limits the scope to relevant tax years and income sources. Do I have to meet CRA auditors in person? No, Mackisen manages all correspondence and submissions on your behalf. Can CRA seize my documents during an audit? Only with proper authorization — Mackisen ensures all requests are legal and proportionate. Can penalties be removed after an audit? Absolutely — Mackisen secures relief through the Taxpayer Relief Program.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s top defense team for CRA audits and reassessments. Our integrated CPAs and tax lawyers bring decades of experience managing audits, defending taxpayers, and negotiating settlements. We act strategically, respond intelligently, and defend fearlessly — because an audit should be about accuracy, not intimidation. When CRA audits you, Mackisen audits them back. Call Mackisen CPA Auditors Montreal today for your 2025 CRA Audit Representation Consultation. The first meeting is free, and your protection starts immediately.