CRA Criminal Investigation (CID) Audit — Montreal CPA Firm Near You: Prevent Prosecution

A CRA Criminal Investigation Division (CID) Audit represents the most serious level of tax enforcement in Canada. When the Canada Revenue Agency suspects fraud, false statements, or deliberate tax evasion, it escalates a standard audit into a criminal investigation. This shift activates your Charter rights and significantly raises the legal stakes.
Mackisen CPA Montreal provides immediate, discreet, and strategic defense in CRA criminal tax cases — protecting your rights, reconstructing your records, and preventing charges before they lead to prosecution.

Legal Foundation

Law: Income Tax Act s.239 (tax evasion and false statements), Criminal Code s.380 (fraud), Excise Tax Act s.325 (false return offences).
Jurisprudence: R. v. Jarvis (2002 SCC) — once CRA’s primary purpose changes from audit to prosecution, taxpayers are entitled to full Charter protections, including the right to silence and counsel.

Learning insight: CRA’s CID audits don’t question your accounting — they question your intent. Mackisen CPA ensures your intent is proven as compliant, not criminal.

Why CRA Initiates Criminal Investigations

The CRA’s Criminal Investigations Division intervenes when evidence suggests willful non-compliance. Common triggers include:

• Repeated or deliberate underreporting of income.

• False or duplicated invoices or expenses.

• Undeclared offshore accounts or cash deposits.

• Unreported crypto or digital-asset gains.

• Informant tips, whistleblower submissions, or suspicious-activity reports from financial institutions.

Learning insight: CRA doesn’t act on assumption — it acts on patterns. Mackisen CPA identifies those patterns early and reframes them as administrative errors, not criminal behavior.

How CRA CID Investigations Work

1. Audit Escalation: A civil audit uncovers potential intent to evade or misrepresent.

2. Intelligence Gathering: CRA CID gathers banking data, supplier invoices, and third-party information.

3. Search Warrant Execution: CRA, often with RCMP support, may seize computers, ledgers, or digital files.

4. Forensic Accounting Analysis: CRA examines data for evidence of deliberate concealment.

5. Prosecution Referral: Files are referred to the Public Prosecution Service of Canada (PPSC) for criminal proceedings.

Learning insight: When a file turns criminal, the best defense is immediate professional intervention. Mackisen CPA acts before CRA finalizes its evidence narrative.

Mackisen CPA’s Criminal Investigation Defense Strategy

1. File Assessment: Determine if CRA’s dominant purpose is civil or criminal.

2. Evidence Control: Ensure all documentation is accurate, consistent, and legally compliant.

3. Forensic Reconstruction: Rebuild complete financial statements to demonstrate intent to comply.

4. Charter Protection: Coordinate with legal counsel to assert your rights and prevent self-incrimination.

5. Voluntary Disclosure Evaluation: When applicable, file a voluntary disclosure before prosecution begins.

Learning insight: CRA prosecutes for intent — Mackisen CPA defends with documentation. Facts win cases, not fear.

Common Offences Under CRA CID Audits

• Filing false tax returns or GST/HST claims.

• Claiming fake or inflated expenses.

• Failing to report income from cash or crypto sources.

• Structuring transactions to conceal ownership.

• Obstructing CRA auditors or destroying records.

Penalties for conviction can include:

• Fines up to 200% of taxes evaded.

• Imprisonment up to 5 years.

• Public disclosure of conviction on CRA’s website.

Learning insight: CRA doesn’t negotiate once charges are filed — defense starts long before that point.

Real-World Client Success

• A Montréal contractor avoided prosecution after Mackisen CPA proved missing GST filings were due to administrative errors, not fraud.

• A real estate investor cleared a CID case when we demonstrated rental underreporting was caused by software synchronization issues.

• A technology entrepreneur facing criminal allegations over offshore income avoided charges after Mackisen CPA’s voluntary disclosure filing.

Learning insight: CRA’s CID unit seeks intent — Mackisen CPA provides context. Context saves clients.

SEO Optimization and Educational Value

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Learning insight: Online authority is built on clarity — CRA defense is built on facts. Mackisen CPA combines both to protect your reputation and results.

Why Mackisen CPA Montreal

Mackisen CPA Montreal has over 35 years of experience handling CRA and Revenu Québec audits, investigations, and voluntary disclosures. Our bilingual CPAs and forensic accountants collaborate with tax lawyers to provide comprehensive representation and evidence-based defense.
We protect your rights, your financial integrity, and your business reputation throughout every stage of CRA enforcement.

Learning insight: CRA builds criminal cases through documentation — Mackisen CPA dismantles them with stronger documentation.

Call to Action

If CRA or Revenu Québec has contacted you regarding a potential criminal investigation, search warrant, or audit escalation, act immediately.
Contact Mackisen CPA Montreal for confidential and urgent representation.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com

Learning conclusion: CRA Criminal Investigations test honesty under pressure. Mackisen CPA Montreal ensures your intent is proven, your rights are protected, and your case ends in compliance — not conviction.