CRA Corporate Tax Reassessment 2025 — Reverse CRA Errors, Protect Your Profits, and Eliminate Penalties

In 2025, CRA’s Corporate Tax Reassessment Program has become a major source of financial pressure for Canadian businesses. CRA’s audit algorithms now automatically flag corporations with fluctuating income, changing expenses, or intercompany transactions for review. Many reassessments are issued without full context — often based on partial data, system errors, or aggressive interpretation of the law. These reassessments can lead to double taxation, frozen refunds, and devastating interest charges. At Mackisen CPA Auditors Montreal, we defend businesses from unfair corporate tax reassessments. Our CPA auditors and tax lawyers analyze CRA’s adjustments line by line, prove the accuracy of your filings, and negotiate immediate relief. We don’t let CRA’s automation dictate your tax results — we restore fairness and accuracy through law and evidence.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 152(4): Governs CRA’s power to reassess within normal or extended time limits.

• Section 18(1)(a): Allows deduction of legitimate expenses incurred to earn income.

• Section 67: Requires business expenses to be reasonable under the circumstances.

• Section 163(2): Imposes gross negligence penalties, which Mackisen can have reduced or cancelled.

• Section 220(3.1): Enables CRA to remove penalties and interest through the Taxpayer Relief Program.
  Tax Administration Act (Quebec)
  Revenu Québec conducts parallel reassessments for provincial corporate tax, GST/QST, and payroll obligations. Mackisen coordinates both agencies for consistency and optimal relief.

Key Court Decisions

Bédard v. The Queen (2022): CRA must demonstrate factual errors before issuing reassessments.
Thibault v. The Queen (2022): Corporations relying on professional accountants cannot be penalized for honest filing errors.
Guindon v. Canada (2015): Gross negligence penalties require proof of intent, not simple oversight.
Venne v. The Queen (1984): CRA cannot reassess on speculation — the burden of proof lies with them.
These rulings confirm that CRA corporate reassessments can be successfully reversed with proper documentation and advocacy.

Why CRA Reassesses Corporations

CRA’s new audit software cross-matches corporate returns with GST/HST, payroll, and banking records to find inconsistencies. Common 2025 triggers include:

• Disallowed management fees or shareholder loans.

• Year-over-year expense fluctuations.

• Differences between T2 returns and GST filings.

• Late or incomplete documentation requests.

• Intercompany transactions or related-party charges.
  CRA assumes overstatement — Mackisen proves legitimate reporting.

Mackisen’s Corporate Reassessment Defense Strategy

1. Audit File Review: Examine CRA’s reassessment package and determine the underlying error or misinterpretation.

2. Reconciliation: Align financial statements, tax filings, and documentation to eliminate inconsistencies.

3. Legal Defense: Build evidence showing compliance and commercial purpose behind all adjustments.

4. Formal Objection Filing: Submit a Notice of Objection to pause CRA collection and challenge their reassessment.

5. Penalty & Interest Relief: Apply under Section 220(3.1) to remove interest and penalty burdens.
   Our process transforms CRA’s assumptions into documented compliance that restores your financial position.

Real Client Experience

A Montreal construction group was reassessed $418,000 for “unreasonable expenses.” Mackisen proved business necessity and CRA withdrew the reassessment in full.
A Quebec manufacturer faced $252,000 in penalties for “shareholder transactions.” Mackisen provided legal agreements and secured 100% penalty cancellation.

Common Questions

Can CRA reassess multiple years? Yes — up to four years normally, ten for alleged misrepresentation. Mackisen ensures limits are enforced.
Do I have to pay during objection? No — Mackisen files immediately to suspend collection and prevent interest escalation.
Can CRA deny my deductions after approval? Only with proof — Mackisen uses evidence to reinstate every legitimate expense.
Can penalties be cancelled? Yes — Mackisen achieves relief through Section 220(3.1) applications and negotiation.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s trusted defense firm for corporate tax disputes and reassessments. Our team of CPAs, tax lawyers, and financial strategists work together to challenge CRA’s errors and protect your business integrity. We act fast, defend strongly, and win consistently — because your success deserves certainty, not surprises. When CRA reassesses your corporation, Mackisen reassesses their logic.
Call Mackisen CPA Auditors Montreal today for your 2025 Corporate Tax Reassessment Consultation. The first meeting is free, and your protection starts immediately.