CRA Corporate Income Tax Audit — Montreal CPA Firm Near You: Large File Defense

A CRA Corporate Income Tax Audit is one of the most detailed reviews performed by the Canada Revenue Agency (CRA) or Revenue Québec. It targets corporations with complex financial structures, intercompany transactions, or high-value deductions. The purpose of this audit is to ensure that corporate tax returns accurately report income, expenses, and reserves in compliance with the Income Tax Act. Mackisen CPA Montreal provides large-scale defense, data analysis, and documentation management to protect your corporation throughout the audit process.

Legal Foundation

Law: Income Tax Act Part I; Regulations 1100–1101 — sets the framework for corporate income, capital-cost allowance, and reserves.
Jurisprudence: General Motors of Canada v. The Queen (2008 FCA) — clarifies the standards of reasonableness for corporate deductions and transfer-pricing policies.

Why You Need a CPA for a Corporate Income Tax Audit

Corporate audits often involve multiple years and extensive documentation requests. CRA and ARQ auditors analyze financial statements, intercompany loans, transfer pricing, deferred taxes, and management fees. Without professional representation, corporations risk reassessment, penalties, and reputational damage.

Mackisen CPA Montreal manages all audit communication, coordinates with external counsel when necessary, and ensures that corporate filings are defended with both legal authority and accounting logic.

Learning insight: CRA corporate auditors are not just verifying numbers—they are evaluating your governance and documentation systems. A CPA ensures those systems are strong enough to withstand legal and financial scrutiny.

What Mackisen CPA’s Corporate Audit Representation Includes

• Full audit readiness assessment and risk mapping.

• Review of intercompany transactions, management fees, and shareholder loans.

• Preparation of reconciliation schedules for retained earnings and tax adjustments.

• Capital-cost allowance verification and deferred-tax reconciliation.

• Coordination of responses to CRA or ARQ auditors with reference to supporting legislation.

Learning insight: A corporate audit is as much about clarity as compliance. A well-documented explanation is more powerful than a spreadsheet full of numbers.

Common Triggers for Corporate Income Tax Audits

• Significant fluctuations in profit margins.

• Large or recurring losses.

• Related-party transactions lacking written agreements.

• Inconsistent treatment of shareholder benefits.

• High management fees or professional service payments.

• Aggressive tax-planning or GAAR-flagged reorganizations.

Mackisen CPA Montreal identifies these triggers early, preparing strong supporting documentation before the audit begins.

How Mackisen CPA Manages Corporate Audits

1. Conducts a pre-audit diagnostic and identifies high-risk accounts.

2. Builds a full audit file including contracts, minutes, and intercompany agreements.

3. Reviews all CCA, reserves, and allowances in line with ITA Regulations 1100–1102.

4. Drafts detailed responses citing law, case law, and accounting standards.

5. Negotiates with CRA or Revenue Québec auditors to limit audit scope and secure early resolution.

Learning insight: CRA audits work on assumptions; CPA defense works on evidence. Documentation transforms uncertainty into control.

Benefits of Professional Corporate Audit Representation

• Protects corporations from excessive reassessments and penalties.

• Reduces risk of multi-year or multi-entity investigations.

• Preserves compliance credibility with tax authorities.

• Strengthens governance and internal controls.

• Provides a permanent audit-ready documentation framework.

Learning insight: Every corporate audit builds your reputation with regulators. Passing one cleanly demonstrates credibility, stability, and strong financial oversight.

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Learning insight: Corporate audits are about proving that your accounting reflects reality—not perfection. Mackisen CPA turns complex financial structures into transparent, defensible documentation.

Real Client Success

• A technology firm successfully defended a $2.3M audit adjustment by proving intercompany cost-sharing agreements were at arm’s length.

• A real-estate holding company avoided $400,000 in reassessed CCA after Mackisen CPA reconstructed asset valuations and depreciation logs.

• A professional corporation reduced its penalty exposure by 100% after our firm demonstrated proper accrual accounting for deferred revenue.

Why Mackisen CPA Montreal

Mackisen CPA’s corporate audit team includes professionals with deep expertise in both federal and Québec tax law. With over 35 years of combined experience, our firm specializes in multi-entity and multi-year audits that demand precision, strategy, and speed.

Learning insight: CRA’s goal is verification; Mackisen CPA’s goal is protection. We ensure every corporate number, note, and narrative aligns perfectly with the Income Tax Act.

Learning conclusion: A CRA Corporate Income Tax Audit tests not only your numbers but your leadership. With Mackisen CPA Montreal, every response becomes a demonstration of professionalism, control, and corporate integrity.