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

A CRA Criminal Investigation Division (CID) Audit is the most serious enforcement action available to the Canada Revenue Agency. Unlike a standard tax audit — which evaluates accuracy — a CID audit evaluates intent. CRA initiates these investigations when it believes there may be deliberate tax evasion, falsified records, hidden income, or obstruction.
Mackisen CPA Montreal specializes in immediate, discreet, and strategic CID defense. Our role is to protect your rights, reconstruct your records, prevent escalation, and keep the file in the civil stream rather than the criminal stream.

A CID audit is not about errors. It is about whether CRA believes those errors were intentional. Our job is to prove they weren’t — with facts, records, and legal compliance.

Legal Foundation

Income Tax Act s.239 — criminal offences including evasion, fraud, destruction of records, and false statements.
Criminal Code s.380 — fraud provisions often referenced during CID analysis.
Excise Tax Act s.325 — criminal penalties for GST/HST evasion.
Jurisprudence: R. v. Jarvis (2002 SCC) — when CRA’s main purpose shifts from audit to prosecution, Charter rights (silence, counsel, protection against self-incrimination) fully apply.

Learning insight: CID cases hinge on intention. Mackisen CPA ensures your intention is proven as compliant, not criminal.

Why CRA Initiates Criminal Investigations

CRA’s Criminal Investigations Division acts when audit patterns suggest potential fraud. Common triggers include:

• Repeated underreporting of income (cash, crypto, foreign).

• Use of false invoices, sham subcontractors, or duplicate expenses.

• Hidden offshore accounts reported under FATCA or the OECD CRS system.

• POS manipulation or “zapper” (sales-suppression) software.

• Whistleblower allegations under CRA’s Informant Leads Program or OTIP.

• Refusal to provide records or suspected destruction of documents.

Learning insight: CRA does not escalate because of one issue — it escalates when it sees a pattern. Your CPA must break that pattern with evidence.

CID Investigation Process

1. Intelligence review — CRA gathers third-party data, banking records, and past filings.

2. Audit escalation — the file shifts from civil auditors to the Criminal Investigations Division.

3. Search warrants — executed to seize computers, servers, invoices, and digital backups if CRA suspects concealment.

4. Forensic analysis — CRA reviews transactions to evaluate deliberate misreporting.

5. Referral to the Public Prosecution Service of Canada (PPSC) — if CRA believes intent is criminal.

Learning insight: Once the file turns criminal, every word and document becomes evidence. Your CPA must manage the narrative immediately.

Mackisen CPA’s CID Defense Strategy

• Determine whether the file is civil or criminal (critical first step).

• Reconstruct accurate financial records to explain discrepancies.

• Demonstrate that gaps stem from error, not evasion.

• Coordinate with tax and criminal lawyers to protect Charter rights.

• Prepare compliance filings and disclosures where appropriate.

• Manage CRA communication to avoid self-incrimination while maintaining cooperation.

Learning insight: CID defense is not about “talking your way out.” It’s about documenting your way out.

Common Criminal Allegations in CID Audits

• Intentionally unreported cash or digital income

• Fake or altered invoices

• Undisclosed offshore accounts or corporations

• GST/HST refund fraud

• Deliberate false statements or document destruction

• Payroll remittances withheld and used for other purposes

Penalties can include:

• Fines up to 200% of tax evaded

• Imprisonment up to 5 years

• Publication of your conviction on CRA’s website

• Asset seizure under proceeds-of-crime laws

Learning insight: The earlier a CPA intervenes, the greater the chance of redirecting the file back to civil audit and avoiding prosecution.

Real-World Success Stories

• A retailer avoided prosecution when Mackisen CPA proved system errors caused unreported POS sales — not manipulation.

• A contractor prevented charges after we reconstructed cash receipts and supplied a complete audit trail.

• A consultant facing offshore allegations avoided criminal referral when our team demonstrated residency misinterpretation and corrected filings under voluntary disclosure.

Learning insight: CID cases are won by context, reconstruction, and evidence — not by argument.

SEO Optimization and Educational Value

Primary Keywords: CRA Criminal Investigation Audit, CRA CID, Mackisen CPA Montreal, Tax Evasion Defense Canada, CPA Firm Near You, Criminal Tax Audit.
Secondary Keywords: CRA fraud audit, GST/HST criminal audit, CRA search warrant response, voluntary disclosure assistance, criminal tax compliance Montreal.

Learning insight: Authority protects both your SEO and your legal standing. Mackisen CPA gives you both — clarity for Google, compliance for CRA.

Why Mackisen CPA Montreal

Mackisen CPA Montreal brings 35+ years of audit, tax-law, and forensic experience to CID cases. Our bilingual CPAs and forensic accountants collaborate with tax and criminal lawyers to ensure your rights, evidence, and narrative remain aligned and defensible.

Learning insight: CID audits test character and compliance. Mackisen CPA preserves both with structured, strategic, and confidential defense.

Call to Action

If CRA has contacted you under the Criminal Investigations Division, or if you suspect your audit is escalating, act immediately.
Contact Mackisen CPA Montreal for confidential, urgent CID defense support.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com

Learning conclusion: A CRA CID Audit is not a tax review — it is a criminal investigation. Mackisen CPA Montreal ensures your case never gets that far by documenting intent, correcting files, and protecting you with precision and professionalism.