CRA Business Audit 2025 — Protect Your Company, Stop CRA Reassessments, and Eliminate Penalties

In 2025, CRA’s Business Audit and Enforcement Program has reached record intensity. CRA’s advanced AI audit tools now analyze financial statements, GST/HST filings, payroll remittances, and banking activity in real time to identify “anomalies.” Even small inconsistencies between your T2 return and bookkeeping system can trigger a full audit. Businesses across Canada are facing aggressive reviews, denied deductions, and six-figure penalties for errors that are often administrative. At Mackisen CPA Auditors Montreal, we defend small and medium-sized businesses, corporations, and professionals from CRA’s growing scrutiny. Our CPA auditors and tax lawyers build a complete defense strategy that proves compliance, reduces exposure, and resolves audits quickly and confidentially. We don’t let CRA define your business by mistakes — we prove your success through facts and law.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 231.1: Grants CRA authority to inspect records but requires reasonable audit conduct.

• Section 18(1)(a): Allows deduction of expenses incurred to earn business income.

• Section 67: Requires all expenses to be reasonable in the circumstances.

• Section 163(2): Imposes gross negligence penalties, which Mackisen can contest and eliminate.

• Section 220(3.1): Enables CRA to cancel or reduce penalties and interest through the Taxpayer Relief Program.
  Tax Administration Act (Quebec)
  Revenu Québec conducts joint audits for corporate income tax, payroll, and QST. Mackisen manages both jurisdictions to prevent duplicate reassessments and ensure consistent defense.

Key Court Decisions

Bédard v. The Queen (2022): CRA must base audits on facts, not assumptions, and respect taxpayer rights.
Thibault v. The Queen (2022): Proper documentation and professional advice can overturn CRA reassessments.
Guindon v. Canada (2015): Penalties cannot apply to honest or technical errors made in good faith.
Venne v. The Queen (1984): CRA must demonstrate real evidence of negligence before imposing penalties.
These rulings confirm that CRA business audits can be successfully challenged when backed by accurate records and professional representation.

Why CRA Targets Businesses

CRA’s 2025 audit strategy focuses on corporate entities with irregularities in financial or tax data. Common triggers include:

• Inconsistent income reporting across T2, GST/HST, and payroll filings.

• High cash transactions or unexplained deposits.

• Unsubstantiated business expenses or vehicle deductions.

• Repeated losses or declining profitability.

• Unfiled or late returns across multiple years.
  CRA assumes risk — Mackisen proves compliance.

Mackisen’s Business Audit Defense Strategy

1. Risk Review: Analyze CRA’s audit letter and identify high-risk areas of concern.

2. Documentation Reconstruction: Organize receipts, financial records, and reconciliations to validate transactions.

3. Expense Verification: Ensure all deductions are properly documented and linked to business operations.

4. Formal Objection Filing: Submit a detailed Notice of Objection to suspend collection and contest CRA findings.

5. Penalty & Interest Relief: File under Section 220(3.1) to cancel financial penalties and restore business credibility.
   Our structured defense transforms CRA pressure into professional precision and compliance protection.

Real Client Experience

A Montreal construction company faced a $427,000 reassessment for “unverified expenses.” Mackisen provided documentation and CRA cancelled the entire reassessment.
A Quebec logistics firm was penalized $164,000 after CRA questioned vehicle deductions. Mackisen proved business use and secured 100% penalty removal.

Common Questions

Can CRA audit multiple years at once? Yes, but Mackisen ensures CRA’s audit scope stays within legal reassessment limits.
Can CRA seize bank accounts during audit? Yes — but Mackisen halts collections through formal objection and representation.
Do I need to meet CRA in person? Not always — Mackisen represents you directly, minimizing disruption to operations.
Can CRA deny legitimate expenses? Only if undocumented — Mackisen rebuilds evidence and defends every deduction.

Why Mackisen

At Mackisen CPA Auditors Montreal, we have over 25 years of experience defending businesses against CRA and Revenu Québec audits. Our combined legal and accounting expertise ensures every number, deduction, and transaction is protected. We act fast, argue intelligently, and deliver proven results — because your company deserves to grow without fear. When CRA audits your business, 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.