CRA Business Reassessment 2025 — Reverse CRA Errors, Protect Your Company, and Restore Fair Tax Treatment

A CRA Business Reassessment is one of the most financially damaging events a company can face. In 2025, CRA’s automated audit and data-matching systems issue reassessments within days of detecting reporting “inconsistencies.” These reassessments often exaggerate income, disallow valid deductions, and apply harsh penalties and daily compounded interest — leaving business owners with inflated balances they don’t truly owe. The truth? Most CRA reassessments are based on flawed assumptions that can be overturned. At Mackisen CPA Auditors Montreal, we specialize in defending and reversing CRA business reassessments. Our CPA auditors and tax lawyers dissect every number, rebuild the documentation, and prepare powerful appeals that eliminate penalties and reduce tax exposure. We don’t let CRA define your business — we define your defense.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 152(4): Grants CRA the power to reassess returns but limits how far back it can go.

• Section 165(1): Gives taxpayers the right to file a Notice of Objection within 90 days.

• Section 161(1): Establishes interest accrual on reassessed balances until resolved.

• Section 220(3.1): Allows taxpayers to seek penalty and interest relief under the Taxpayer Relief Program.
  Tax Administration Act (Quebec)
  Revenu Québec has identical reassessment powers for provincial tax, QST, and payroll compliance. Mackisen coordinates both audits to ensure consistent, fair outcomes across jurisdictions.

Key Court Decisions

Venne v. The Queen (1984): CRA reassessments can be overturned if the taxpayer provides verifiable documentation.
Guindon v. Canada (2015): CRA penalties can be cancelled under relief provisions when taxpayers act in good faith.
Bédard v. The Queen (2022): Small businesses win appeals when CRA fails to consider contextual and industry realities.
Thibault v. The Queen (2022): Organized, professional documentation is the most powerful weapon against CRA assumptions.
These cases confirm that CRA reassessments can be successfully reversed through timely action and expert defense.

Why CRA Issues Business Reassessments

In 2025, CRA relies on AI to compare corporate filings with payroll, GST/HST, and third-party data. Common triggers include:

• Expense claims exceeding industry averages.

• Late or incomplete filings.

• Differences between CRA and Revenu Québec returns.

• Denied Input Tax Credits (ITCs) or deductions.

• Audit follow-ups where CRA assumes continued non-compliance.
  CRA’s data doesn’t tell your story — Mackisen makes sure your evidence does.

Mackisen’s Business Reassessment Defense Strategy

1. Reassessment Review: Identify legal or factual errors in CRA’s findings.

2. Documentation Reconstruction: Rebuild and verify all accounting records, invoices, and ledgers.

3. Formal Objection Filing: Submit a detailed Notice of Objection to freeze enforcement while the case is reviewed.

4. Negotiation & Resolution: Engage CRA Appeals Officers with a professional case file and clear financial analysis.

5. Relief Application: Request cancellation of penalties and interest under Section 220(3.1).
   Our team fights not only the numbers but the process — ensuring CRA’s reassessment is replaced with the truth.

Real Client Experience

A Montreal logistics company was reassessed $210,000 for “overstated expenses.” Mackisen proved CRA’s calculation errors and secured a 100% reversal of the reassessment.
A Quebec construction business faced dual CRA and Revenu Québec reassessments totaling $178,000. Mackisen reconstructed payroll and expense files, achieving a 75% reduction in total debt.

Common Questions

Can CRA reassess multiple years? Yes — up to 3 years normally, 10 if CRA alleges negligence. Mackisen ensures limits are enforced.
Can CRA collect during an appeal? Not if a valid objection is filed — Mackisen freezes collections while defending your case.
Do I need to pay before appealing? No. Payment is not required while the objection is active.
Can CRA reassess again after appeal? Only in rare cases — Mackisen ensures finality through proper resolution.

Why Mackisen

At Mackisen CPA Auditors Montreal, we transform CRA reassessments into victories. Our firm combines audit precision, legal strength, and negotiation expertise to protect businesses from financial devastation. We know CRA’s system, we know their tactics, and we know how to win. We act fast, fight hard, and restore fairness — because your business deserves the truth, not CRA’s version of it.
Call Mackisen CPA Auditors Montreal today for your 2025 Business Reassessment Defense Consultation. The first meeting is free, and your protection begins immediately.