CRA Corporate Records Audit 2025 — Protect Your Compliance, Prevent Penalties, and Keep Your Business

In 2025, CRA’s Corporate Records Audit Program has become one of the most rigorous compliance checks for Canadian corporations. CRA now uses digital AI verification tools to cross-match minute books, shareholder registers, director filings, and tax returns to detect missing documentation or inconsistencies. If your corporate records are incomplete — even for a single year — CRA can issue reassessments, deny deductions, freeze tax refunds, or impose legal penalties. At Mackisen CPA Auditors Montreal, we protect businesses from costly compliance mistakes. Our CPA auditors and tax lawyers organize, audit-proof, and correct your corporate records, ensuring full legal alignment under federal and provincial regulations. We don’t let missing paperwork threaten your company’s future — we build a defense that keeps you compliant and protected.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 230(1): Requires corporations to maintain complete books and records at their principal place of business.

• Section 231.1: Grants CRA authority to inspect, audit, or request corporate records at any time.

• Section 152(4): Allows reassessment of prior years if CRA suspects incomplete documentation.

• Section 220(3.1): Permits CRA to waive penalties and interest through the Taxpayer Relief Program.
  Canada Business Corporations Act (CBCA)

• Sections 19–21: Mandate corporations to maintain accurate minute books, share registers, and director information.
  Tax Administration Act (Quebec)
  Revenu Québec performs parallel record verification for provincial filings, payroll, and QST accounts. Mackisen synchronizes both audits for consistent results and minimal disruption.

Key Court Decisions

Bédard v. The Queen (2022): CRA must consider reasonable explanations and reconstructed documentation before imposing penalties.
Thibault v. The Queen (2022): Properly maintained minute books are sufficient to defend against CRA record-keeping allegations.
Guindon v. Canada (2015): Honest administrative oversight does not justify gross negligence penalties.
Venne v. The Queen (1984): CRA cannot issue arbitrary reassessments without factual evidence of missing or falsified records.
These rulings confirm that CRA corporate record audits can be successfully defended with proper documentation and professional representation.

Why CRA Targets Corporate Records

CRA focuses on corporate record audits because incomplete files often signal deeper compliance gaps. Common 2025 triggers include:

• Missing or outdated corporate minute books.

• Unrecorded director or shareholder changes.

• Lack of resolutions for dividends, bonuses, or loans.

• Mismatch between share registers and T5 filings.

• Delayed or missing government filings under the CBCA or provincial acts.
  CRA assumes non-compliance — Mackisen proves legal diligence.

Mackisen’s Corporate Records Audit Defense Strategy

1. Audit Review: Evaluate CRA’s record request and identify compliance risks or missing documentation.

2. Minute Book Reconstruction: Rebuild resolutions, share registers, and director filings to restore compliance.

3. Corporate Filing Coordination: Align filings across CRA, Corporations Canada, and Revenu Québec.

4. Objection and Representation: File a Notice of Objection if CRA applies penalties or disallows tax filings.

5. Penalty and Interest Relief: Apply under Section 220(3.1) for administrative relief once compliance is re-established.
   Our approach turns audit exposure into documentation excellence, safeguarding both your legal standing and financial health.

Real Client Experience

A Montreal consulting firm faced a $94,000 reassessment for “missing corporate records.” Mackisen reconstructed five years of minute books and CRA cancelled the entire reassessment.
A Quebec family business was penalized for “undocumented dividends.” Mackisen produced retroactive resolutions and secured full penalty elimination.

Common Questions

Can CRA penalize missing corporate records? Yes — but Mackisen can rebuild and validate your records to remove penalties.
Do I need to maintain a minute book every year? Yes — CRA and Corporations Canada both require annual resolutions and director updates.
Can CRA audit old corporate records? Yes — typically within six years, longer if CRA alleges misrepresentation. Mackisen ensures compliance backdating where necessary.
What happens if my lawyer or accountant lost the records? Mackisen reconstructs them legally with backup data and evidence.

Why Mackisen

At Mackisen CPA Auditors Montreal, we combine accounting precision, corporate law expertise, and tax audit strategy to keep your business fully protected. Our team ensures your corporation is not only audit-ready but also legally fortified against CRA scrutiny. We act fast, document thoroughly, and defend fearlessly — because compliance is not optional, it’s your corporate shield. When CRA audits your records, Mackisen audits their accuracy.
Call Mackisen CPA Auditors Montreal today for your 2025 Corporate Records Audit Defense Consultation. The first meeting is free, and your protection starts immediately