CRA Corporate Tax Reassessment 2025 — Challenge CRA’s Findings, Reduce Tax Debt, and Eliminate Penalties with Mackisen

In 2025, CRA’s Corporate Reassessment Division is targeting more small and mid-sized businesses than ever before. Using data-matching and AI algorithms, CRA is re-auditing corporations that were previously considered compliant — often reassessing income, denying deductions, or questioning management fees and shareholder transactions. Many corporations are receiving six-figure reassessments and 50% gross negligence penalties without clear justification. At Mackisen CPA Auditors Montreal, we defend corporations against unfair CRA reassessments. Our CPA auditors and tax lawyers dissect CRA’s logic, rebuild evidence, and negotiate reversals or settlements. We don’t let CRA’s technology rewrite your tax history — we bring facts, law, and strategy back into focus.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 152(4): Allows CRA to reassess corporate returns within three years unless there is misrepresentation or fraud — Mackisen ensures this limitation is enforced.

• Section 18(1)(a): Defines deductible business expenses; CRA often overreaches here, and Mackisen restores proper claims.

• Section 67: Requires that all corporate expenses be reasonable — Mackisen uses benchmarks and documentation to prove compliance.

• Section 163(2): Governs gross negligence penalties, which Mackisen removes through factual defense and legal precedent.

• Section 220(3.1): Enables CRA to cancel or reduce penalties and interest under the Taxpayer Relief Program.
  Tax Administration Act (Quebec)
  Revenu Québec mirrors CRA’s reassessment rules but applies separate audits for QST, payroll, and income taxes. Mackisen coordinates both agencies for unified defense and complete relief.

Key Court Decisions

Bédard v. The Queen (2022): CRA cannot issue reassessments without factual evidence of misrepresentation.
Thibault v. The Queen (2022): Corporations maintaining reasonable documentation are protected from penalties.
Guindon v. Canada (2015): Honest reliance on professional accountants negates gross negligence.
Jordan v. The Queen (2009): CRA must allow reasonable time and procedural fairness before reassessment.
These decisions confirm that CRA must justify every reassessment with fact, fairness, and legal validity.

Why CRA Reassesses Corporations

CRA’s 2025 reassessment surge targets corporations that show statistical or transactional anomalies. Common triggers include:

• Related-party transactions without formal documentation.

• Management fees or bonuses viewed as unreasonable.

• Intercompany loans or shareholder advances.

• Significant shifts in income or deductions year-over-year.

• Late or missing T2 filings.
  CRA assumes misrepresentation — Mackisen proves professional compliance.

Mackisen’s Corporate Reassessment Defense Strategy

1. Assessment Review: Examine CRA’s reassessment and identify errors in calculation or legal interpretation.

2. Evidence Reconstruction: Rebuild accounting records, resolutions, and intercompany agreements to prove compliance.

3. Formal Objection Filing: Submit a Notice of Objection within 90 days to stop CRA collection and preserve your rights.

4. Appeals Representation: Negotiate with CRA Appeals Officers using financial analysis and legal precedent.

5. Penalty & Interest Relief: File under Section 220(3.1) to cancel penalties due to administrative or procedural error.
   Our strategy ensures CRA’s reassessment doesn’t become your company’s burden.

Real Client Experience

A Montreal manufacturing company was reassessed $486,000 for “unreasonable management fees.” Mackisen provided documentation and CRA withdrew the full reassessment.
A Quebec construction firm was hit with $238,000 in penalties for “missing shareholder loan records.” Mackisen reconstructed financials and CRA cancelled all penalties.

Common Questions

Can CRA reassess my corporation multiple times? Only within legal limits — Mackisen enforces statutory protection under Section 152(4).
Can CRA deny my expenses after approval in past years? No — Mackisen ensures CRA respects consistency and precedent.
Can CRA charge penalties during dispute? Yes, but Mackisen suspends collection with a formal objection.
Can penalties and interest be waived? Absolutely — Mackisen secures full relief through the Taxpayer Relief Program.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leading defenders of corporations facing CRA reassessment. Our integrated team of CPAs and tax lawyers combines financial expertise with legal precision to overturn unfair decisions and restore corporate confidence. We act decisively, document thoroughly, and negotiate relentlessly — because CRA should never redefine your business success. When CRA reassesses your company, Mackisen reassesses their evidence.
Call Mackisen CPA Auditors Montreal today for your 2025 Corporate Reassessment Defense Consultation. The first meeting is free, and your protection starts immediately.