CRA Corporate Income Tax Audit — Montreal CPA Firm Near You: Large File Defense

A CRA Corporate Income Tax Audit is a detailed and multi-layered review of a corporation’s financial records to confirm the accuracy of income, deductions, credits, and intercompany transactions. These audits are more extensive than small-business reviews and often span several fiscal years.
Mackisen CPA Montreal provides large-file audit defense for corporations, professional firms, and holding companies — ensuring your financial records meet CRA’s documentation and commercial-reality standards.

Legal Foundation

Law: Income Tax Act ss.231.1–231.2 (CRA’s right to inspect and demand records); s.247 (transfer pricing adjustments); and Regulations 1100–1102 (capital cost allowance).
Jurisprudence: General Motors of Canada v. The Queen (2008 FCA) — confirmed CRA’s authority to assess intercompany transactions for fair-market value and commercial purpose.

Learning insight: CRA doesn’t question your business — it questions your logic. Mackisen CPA ensures your records show both profitability and compliance.

Why CRA Targets Corporations

CRA uses data analytics, benchmarking, and cross-file matching to identify corporations with potential non-compliance risks.
Common audit triggers include:

• Large intercompany transactions or management fees.

• Unusual or recurring losses.

• High capital asset purchases or accelerated CCA claims.

• Aggressive tax credits (SR&ED, investment, or manufacturing).

• Unfiled or inconsistent T2 schedules.

Learning insight: CRA audits ratios and relationships, not revenue. Mackisen CPA ensures every ratio tells a compliant story.

CRA’s Corporate Audit Process

1. Notice of Audit: CRA outlines the fiscal years, issues, and records requested.

2. Preliminary Review: CRA analyzes financial statements, tax returns, and related schedules.

3. On-Site Examination: Auditors may review accounting systems, invoices, and bank reconciliations.

4. Testing Phase: CRA cross-checks key accounts (revenues, CCA, payroll, GST, and intercompany balances).

5. Proposal Letter: CRA issues preliminary findings; Mackisen CPA responds before reassessment.

Learning insight: CRA’s process is a test of readiness — Mackisen CPA ensures you’re always two steps ahead.

Mackisen CPA’s Corporate Audit Defense Framework

1. Financial Reconciliation: Cross-verify your general ledger with CRA’s target schedules (1, 8, 50, 100).

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

3. Intercompany Documentation: Prove fair-market pricing and legitimate services under s.247.

4. Capital Asset Verification: Recalculate depreciation to match ITA and Regulation 1100.

5. Tax Credit Defense: Document SR&ED or other claims with project and cost evidence.

6. CRA Representation: Manage communication, meetings, and file submission directly.

Learning insight: CRA decisions depend on the quality of your documentation — not the size of your corporation. Mackisen CPA ensures both are audit-ready.

Common CRA Adjustments

• Disallowed management or consulting fees.

• Reclassified shareholder loans as taxable benefits.

• Denied SR&ED or investment credits for lack of technical proof.

• Adjusted depreciation (CCA) for mixed-use assets.

• Transfer-pricing adjustments between related entities.

Mackisen CPA identifies these vulnerabilities early and builds proactive defenses based on law, audit precedent, and evidence.

Learning insight: CRA penalties cost more than prevention — Mackisen CPA’s preparation pays for itself.

Real-World Corporate Audit Results

• A manufacturing group avoided a $940,000 reassessment after Mackisen CPA reconciled intercompany service charges and provided transfer-pricing documentation.

• A professional corporation reversed a $250,000 management-fee disallowance when we supplied contracts and meeting minutes supporting payments.

• A technology startup recovered $420,000 in denied SR&ED credits after Mackisen CPA restructured its technical documentation.

Learning insight: CRA respects consistency — Mackisen CPA makes consistency your strongest defense.

SEO Optimization and Educational Value

Primary Keywords: CRA Corporate Income Tax Audit, Mackisen CPA Montreal, CPA Firm Near You, CRA Large Business Audit, Corporate Tax Reassessment Defense, CRA Intercompany Audit.
Secondary Keywords: CRA SR&ED audit, CRA capital asset review, Mackisen CPA defense Montreal, CRA corporate tax compliance, corporate audit help Québec.

Learning insight: Google and CRA both reward structure — Mackisen CPA creates it in your systems and your SEO.

Why Mackisen CPA Montreal

With more than 35 years of combined experience in corporate taxation, CRA audit defense, and forensic accounting, Mackisen CPA Montreal is a trusted partner for corporations across Québec. Our bilingual team works directly with CRA auditors and legal counsel to ensure every transaction meets both the letter and spirit of the law.

Learning insight: CRA tests precision — Mackisen CPA turns precision into protection.

Call to Action

If your corporation has received a CRA audit notice or information request, act before the reassessment is issued.
Contact Mackisen CPA Montreal today for professional corporate audit defense, documentation review, and compliance alignment.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com

Learning conclusion: CRA Corporate Audits test your documentation, not your decisions. Mackisen CPA Montreal ensures your records withstand scrutiny — turning CRA challenges into opportunities for stronger compliance and corporate credibility.