CRA Business Audit 2025 — Defend Your Company, Eliminate Risk, and Win Against CRA with Mackisen CPA Auditors Montreal

A CRA Business Audit is one of the most stressful events a company can face — and in 2025, CRA’s audit system has become faster, smarter, and tougher than ever. Using AI and industry benchmarking, the CRA automatically identifies “high-risk” businesses based on their filings, expenses, or patterns that deviate from the norm. Once flagged, CRA auditors dig into every account, invoice, and deduction — often without understanding the reality of how small and mid-sized companies operate. But here’s the truth: most CRA business audits can be controlled, defended, and even won when handled strategically. At Mackisen CPA Auditors Montreal, we represent businesses across Canada in CRA and Revenu Québec audits. Our CPA auditors and tax lawyers respond immediately, prepare airtight documentation, and negotiate directly with CRA to protect your company, reduce penalties, and secure compliance. We don’t just survive audits — we dominate them.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 231.1: Grants CRA authority to inspect all books, records, and supporting documents.

• Section 231.2: Allows CRA to compel information from third parties such as banks or clients.

• Section 152(1): Authorizes reassessment after an audit.

• Section 163(2): Establishes penalties for gross negligence or false statements.
  Tax Administration Act (Quebec)
  Revenu Québec conducts parallel audits on payroll, QST, and income tax, often sharing data with CRA. Mackisen ensures both agencies are handled together with a unified defense strategy.

Key Court Decisions

Venne v. The Queen (1984): CRA may estimate income when records are incomplete, but taxpayers can challenge with credible documentation.
Guindon v. Canada (2015): Penalties can be waived if taxpayers demonstrate good faith and diligence.
Bédard v. The Queen (2022): Courts favor taxpayers who maintain proper records and professional representation.
Thibault v. The Queen (2022): CRA must justify audit findings with evidence, not assumptions.
These decisions confirm that CRA’s conclusions are not law — they are negotiable, challengeable, and reversible with the right defense.

Why CRA Audits Businesses

CRA business audits are often triggered by data mismatches, financial anomalies, or reporting trends that appear “too good to be true.” The most common 2025 triggers include:

• High expense or deduction ratios.

• Unusual fluctuations in income or profit.

• Repeated business losses or unfiled tax returns.

• Missing payroll or GST/HST remittances.

• Discrepancies between CRA and Revenu Québec filings.
  Once selected, your business could face a full audit of income, expenses, payroll, and shareholder transactions — unless Mackisen steps in early to narrow the scope.

Mackisen’s Business Audit Defense Strategy

1. Scope Identification: Analyze CRA’s audit notice to identify exactly what they’re targeting.

2. File Reconstruction: Rebuild accounting and tax records to address every potential gap before CRA reviews them.

3. Direct Representation: Handle all communication with CRA on your behalf to avoid misstatements or over-disclosure.

4. Audit Defense & Negotiation: Provide evidence, financial analysis, and legal arguments to counter CRA assumptions.

5. Post-Audit Protection: File objections, relief applications, or appeals as needed to eliminate penalties or reassessments.
   Our strategy is proactive, precise, and proven to protect your business from CRA overreach.

Real Client Experience

A Montreal logistics company was audited for “unreported cash sales” totaling $184,000. Mackisen reconstructed the books, proved all transactions legitimate, and CRA withdrew the entire reassessment.
A Quebec tech firm faced a joint CRA/Revenu Québec audit for payroll compliance. Mackisen identified CRA calculation errors and secured a 92% reduction in penalties and interest.

Common Questions

How long does a CRA business audit take? Most audits last 3–6 months, but Mackisen shortens timelines through full cooperation and documentation.
Can CRA audit multiple years? Yes — typically three, but up to ten in cases of alleged negligence.
Can CRA visit my business? Yes, but Mackisen ensures your rights are protected during every on-site visit.
Can I stop the audit from escalating? Yes — professional representation often prevents audits from turning into reassessments or court cases.

Why Mackisen

At Mackisen CPA Auditors Montreal, we defend your company with precision, authority, and care. Our dual CPA and legal team has decades of experience in corporate audits, objections, and appeals — giving you the expertise needed to confront CRA and win. We act fast, speak their language, and protect your business as if it were our own. When CRA audits your company, Mackisen audits their process.
Call Mackisen CPA Auditors Montreal today for your 2025 Business Audit Defense Consultation. The first meeting is free, and your protection starts immediately.