CRA Business Audit Review 2025 — Correct CRA Errors, Defend Your Records, and Protect Your Company with Mackisen CPA

CRA’s Business Audit Review Division is expanding its use of AI and financial data tracking to target small and medium-sized enterprises. Many businesses are being reassessed for errors that don’t exist, such as misclassified expenses, missing documentation, or overstated deductions. CRA’s automated audit reviews are often based on incomplete information, leading to inflated reassessments and penalties that can cripple operations. At Mackisen CPA Auditors Montreal, we protect your company from unfair business audits and ensure CRA’s findings are fully corrected. Our CPA auditors and tax lawyers prepare comprehensive documentation reviews, negotiate directly with CRA officials, and restore your corporate compliance. We don’t let CRA assumptions rewrite your financial story — we defend it with facts and evidence.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 152(1): Gives CRA authority to assess returns but requires factual accuracy and supporting evidence. Section 18(1)(a): Allows deduction of business expenses used to earn income — Mackisen ensures proper classification and documentation. Section 67: Mandates that expenses must be reasonable and business-related. Section 230(1): Requires businesses to keep records for six years, which Mackisen helps maintain for CRA compliance. Section 220(3.1): Authorizes CRA to cancel penalties and interest through the Taxpayer Relief Program when mistakes are reasonable.
Tax Administration Act (Quebec) Revenu Québec conducts parallel reviews of provincial corporate filings and deductions. Mackisen coordinates both agencies to maintain consistent results and prevent duplicate audits.

Key Court Decisions

Bédard v. The Queen (2022): CRA must justify assessments with verified financial data. Thibault v. The Queen (2022): Reasonable documentation and commercial purpose protect deductions from denial. Guindon v. Canada (2015): Administrative error does not equal gross negligence. Jordan v. The Queen (2009): CRA must evaluate taxpayer fairness and act in good faith. These cases affirm that accurate records and professional representation are the best defense against unfair CRA audits.

Why CRA Targets Businesses for Review

CRA’s automated systems analyze expense patterns and compare industry benchmarks. Common 2025 audit triggers include unusually high travel or advertising costs, GST/HST refund claims, related-party transactions, and missing T4A or subcontractor filings. CRA assumes irregularity — Mackisen proves legitimate business purpose.

Mackisen’s Business Audit Review Strategy

1. Audit File Analysis: Examine CRA’s report, identify discrepancies, and detect procedural violations. 2. Documentation Reconstruction: Rebuild missing records, invoices, and ledgers to support deductions. 3. Communication Management: Handle all correspondence with CRA to ensure your file is properly represented. 4. Negotiation and Adjustment: Present factual corrections and negotiate the withdrawal or reduction of assessments. 5. Penalty & Interest Relief: File a Taxpayer Relief request under Section 220(3.1) to remove financial penalties. Mackisen’s method ensures CRA’s assessments reflect facts, not assumptions.

Real Client Experience

A Montreal marketing company was reassessed $216,000 for “unreasonable expenses.” Mackisen provided proof of business intent and CRA reversed the entire reassessment. A Quebec importer was fined $82,000 after a GST refund review. Mackisen proved filing accuracy and CRA cancelled all penalties.

Common Questions

Can CRA audit my business every year? Yes, but Mackisen minimizes risk through proactive compliance. Can CRA disallow my deductions? Only if not properly supported — Mackisen ensures every expense is backed by documentation. Can CRA penalties be cancelled after audit? Absolutely — Mackisen secures full relief through the Taxpayer Relief Program. Can CRA freeze my business account during audit? Yes, but Mackisen prevents enforcement through immediate negotiation.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s experts in business audit reviews and CRA defense. Our team of CPAs and tax lawyers combines technical precision with legal strategy to correct CRA findings and protect your company. We act fast, document clearly, and argue intelligently — because success belongs to businesses that defend their rights. When CRA audits your business, Mackisen audits their accuracy. Call Mackisen CPA Auditors Montreal today for your 2025 Business Audit Review Consultation. The first meeting is free, and your protection starts immediately.