CRA Corporate Tax Reassessment — Montreal CPA Firm Near You: Defend Against Retroactive Adjustments and Penalties

A CRA Corporate Tax Reassessment is a formal review of your business’s tax filings after they have been submitted. When CRA identifies discrepancies, underreporting, or issues that require adjustment, they issue a reassessment, often resulting in additional tax, penalties, and interest.
Mackisen CPA Montreal helps corporations defend against these reassessments by providing thorough documentation, strategic tax adjustments, and CPA-certified evidence to challenge CRA’s findings. We focus on preventing significant financial exposure and preserving your business’s financial integrity.

Reassessments can affect corporate income, COGS, capital gains, tax credits, or intercompany transactions. A strong defense strategy ensures that your corporation’s tax position is accurate and compliant with the Income Tax Act.

Legal Foundation

Income Tax Act s.152(4) — allows CRA to reassess tax filings within three years from the initial assessment, or longer if tax avoidance is suspected.
Income Tax Act s.152(7) — CRA may reassess based on incomplete or inaccurate information, even after an initial filing.
Income Tax Act s.248(1) — defines income, expenses, and taxation methods subject to review and adjustment by CRA.
Jurisprudence: Canderel Ltd. v. Canada (1998 SCC) — reassessment is legal when there are discrepancies between the taxpayer’s filings and commercial reality.

Learning insight: A reassessment is a correction — but it’s not always a correction of facts. It’s often a correction of interpretation. Your CPA ensures the facts are correct and clearly presented.

Why CRA Initiates Corporate Tax Reassessments

CRA reassesses corporate filings when they suspect:
• significant discrepancies between reported income and third-party information (e.g., T4/T5 slips, invoices, payments)
• non-deductible expenses being claimed, such as personal expenses or capital costs
• GST/HST/QST miscalculations on interprovincial or international transactions
• large, unexplained fluctuations in profits or expenses from year to year
• failure to account for intercompany transactions, related-party fees, or transfer pricing
• unreported or underreported capital gains
• inaccuracies in SR&ED claims or investment tax credits

Learning insight: Reassessments are triggered by discrepancies — not necessarily errors. Consistency in your documentation helps prevent them.

CRA’s Corporate Tax Reassessment Process

1. CRA sends a reassessment notice, outlining changes made to your corporate tax position.

2. The reassessment often involves higher income, denied deductions, or unpaid taxes, along with penalties and interest.

3. Mackisen CPA evaluates the reassessment, analyzes the CRA’s reasoning, and determines whether it can be challenged.

4. We compile the documentation and evidence to support the original position.

5. Our team responds to CRA, submitting a formal objection and requesting a review or adjustment.

6. CRA may issue an adjustment after reviewing your objections or escalate the matter to a tax court if the issue is unresolved.

Learning insight: A reassessment is an opportunity to clarify. The more prepared your CPA is, the more likely the reassessment will be reversed or adjusted in your favor.

Mackisen CPA’s Reassessment Defense Strategy

• carefully review reassessment notices to identify key issues
• prepare a detailed defense based on income, expenses, COGS, and other contested issues
• provide relevant financial documentation such as ledgers, contracts, T4/T5 slips, and invoices
• challenge tax misinterpretations using established tax principles and industry practices
• address penalties and interest calculations by showing good-faith compliance
• file formal objections with supporting documentation to challenge CRA's findings
• negotiate directly with CRA officers to reach a favorable resolution
• prepare for tax court representation when necessary

Learning insight: A reassessment is not the final word. Documentation and expert representation are often the key to reversing or reducing the impact.

Common Corporate Reassessment Issues

• disallowed business expenses that are personal in nature (e.g., home office, vehicle use)
• GST/HST misreporting for multi-jurisdictional transactions
• capital expenditures wrongly deducted as expenses
• SR&ED claims denied due to insufficient technical documentation
• intercompany transactions challenged under transfer pricing rules
• unreported capital gains or improperly classified income

Learning insight: Reassessments often hinge on interpretations of tax law. Mackisen CPA ensures your tax law interpretations hold up to CRA scrutiny.

Real-World Results

• A tech company reduced a $400,000 reassessment after Mackisen CPA documented legitimate subcontractor payments and demonstrated valid CCA claims.
• A manufacturing corporation overturned a $200,000 adjustment by showing transfer-pricing compliance for intercompany transactions and properly documenting cross-border trade.
• A professional services firm saved $150,000 in penalties and interest after Mackisen CPA reconstructed accurate SR&ED claims and provided CRA with required technical documentation.

Learning insight: The more thorough your initial submission, the less likely CRA is to reopen the file. Your CPA ensures your submissions are unassailable.

SEO Optimization and Educational Value

Primary keywords: CRA corporate tax reassessment, tax audit defense, Mackisen CPA Montreal, corporate audit defense, corporate tax adjustment
Secondary keywords: CRA income tax review, GST/HST reassessment, SR&ED claim audit, transfer pricing audit, tax reassessment objection

Learning insight: SEO success thrives on the same principles as CRA defense: Clarity, consistency, and documentation. We ensure both are flawless.

Why Mackisen CPA Montreal

Mackisen CPA Montreal specializes in handling corporate tax reassessments, including multi-jurisdictional, cross-border, and industry-specific issues. Our team has over 35 years of experience helping businesses defend their tax filings against CRA’s audit actions. We provide a strategic defense, using industry knowledge and detailed evidence to ensure your business remains compliant and financially protected.

Learning insight: Corporate audits aren’t just about defending taxes — they are about strategic advocacy. We advocate for your financial well-being with every document and calculation.

Call to Action

If CRA has issued a corporate tax reassessment or proposed an adjustment, don’t wait for penalties to accumulate.
Contact Mackisen CPA Montreal for immediate audit defense, documentation assistance, and strategic negotiation.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com

Learning conclusion: A CRA corporate tax reassessment doesn’t have to mean financial disaster. With Mackisen CPA Montreal on your side, we turn reassessments into opportunities for clarification and financial protection.