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 and complex reviews a business can face. It focuses on large corporations, incorporated professionals, and medium-sized enterprises whose filings involve intercompany transactions, capital assets, and tax credits.
Mackisen CPA Montreal provides complete end-to-end corporate audit representation — analyzing every journal entry, schedule, and tax adjustment to ensure your organization passes with full compliance and zero penalties.

Legal Foundation

Law: Income Tax Act Part I (Corporation Taxation), s.231.1–231.2 (CRA audit powers), and Regulation 1100–1101 (capital cost allowances).
Jurisprudence: General Motors of Canada v. The Queen (2008 FCA) — confirmed CRA’s authority to test intercompany pricing, reserve claims, and expense reasonableness.

Learning insight: Corporate audits are not about errors — they’re about explanations. Mackisen CPA ensures every number tells a legal, logical, and defensible story.

Why CRA Targets Corporations for Audit

CRA uses data analytics to identify corporations with large deductions, unusual losses, or intercompany transactions that deviate from industry norms. A corporate audit may include:

• Intercompany management fees or related-party loans.

• Capital asset purchases and depreciation.

• Revenue recognition timing.

• Research and development (SR&ED) credits.

• Shareholder loans or bonuses.

• Foreign income or transfer-pricing documentation.

Learning insight: The larger your business, the more visible your data. Mackisen CPA makes visibility your greatest compliance strength.

How CRA Conducts a Corporate Income Tax Audit

1. Pre-Audit Screening: CRA’s Large Business Audit Division analyzes filings over multiple years.

2. Information Request (RFI): CRA requests access to financial statements, ledgers, and supporting contracts.

3. On-Site Review: CRA visits your premises or accountant’s office to review books, systems, and reconciliations.

4. Third-Party Verification: CRA may contact suppliers, banks, or affiliates to confirm data.

5. Audit Conclusion: CRA issues a proposed reassessment (Waiver Form T2029) before finalizing.

Learning insight: CRA’s audit is a financial microscope — Mackisen CPA ensures the lens sees order, not risk.

Mackisen CPA’s Corporate Audit Defense Framework

1. Financial Reconstruction: We rebuild your accounting files year by year to match CRA’s test points.

2. Expense Validation: Match all major deductions to invoices, contracts, or journal entries.

3. Capital Asset Reconciliation: Review depreciation schedules and ensure CCA aligns with ITA Regulation 1100.

4. Intercompany Transaction Documentation: Prove commercial substance of all related-party transactions.

5. Tax Credit Review: Validate SR&ED, manufacturing, or investment credits with project documentation.

6. Legal Liaison: Work with your tax counsel to ensure procedural fairness and avoid double taxation.

Learning insight: A corporate audit defense isn’t built from numbers — it’s built from logic. Mackisen CPA builds both.

Common CRA Focus Areas for Corporate Audits

• Revenue Recognition: CRA ensures income is recorded in the correct period.

• Expense Classification: Misclassified capital expenses are disallowed as current deductions.

• Management Fees: CRA tests arm’s-length pricing and service proof.

• Shareholder Benefits: Loans or non-business expenses can be recharacterized as taxable benefits.

• RDTOH/Part IV Tax Refunds: CRA confirms dividend refunds only if conditions are met.

• SR&ED Claims: CRA demands scientific proof for innovation tax credits.

Learning insight: CRA doesn’t just audit books — it audits your decision-making. Mackisen CPA documents every choice to show commercial logic, not intent to evade.

Case Study: How Mackisen CPA Wins Corporate Audits

1. A Québec manufacturer avoided a $420,000 reassessment when Mackisen CPA demonstrated that inventory variances resulted from year-end cut-off, not unreported income.

2. A professional corporation defended $150,000 in management fees after we proved legitimate service contracts between entities.

3. A technology company recovered $80,000 in denied SR&ED credits by submitting technical project logs that CRA had originally overlooked.

Learning insight: CRA closes files faster when faced with structure. Mackisen CPA builds that structure before CRA finishes its review.

SEO Optimization and Learning Value

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Secondary Keywords: CRA business audit Montreal, CRA corporate expense audit, RDTOH refund verification, CRA SR&ED defense, corporate accounting audit Montreal.

Learning insight: The same organization that passes CRA audits also ranks higher on Google — because precision and credibility drive both systems.

Why Mackisen CPA Montreal

With over 35 years of experience in corporate tax and audit representation, Mackisen CPA Montreal is recognized for its high-standard compliance defense. We represent corporations in manufacturing, retail, professional services, and technology across Québec. Our bilingual CPA team aligns your tax, accounting, and legal strategies to withstand CRA scrutiny and achieve audit closure efficiently.

Learning insight: Corporate compliance isn’t just protection — it’s performance. Mackisen CPA ensures your financial governance becomes your greatest business advantage.