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

A CRA Criminal Investigation (CID) Audit is one of the most serious actions a taxpayer or business can face. It occurs when the Canada Revenue Agency (CRA) or Revenue Québec suspects intentional tax evasion, falsified records, unreported income, or fraudulent GST/QST refund claims. Unlike a standard audit, a CID audit can lead to criminal prosecution, asset seizure, or imprisonment. Mackisen CPA Montreal provides immediate defense coordination, forensic accounting, and compliance restoration to prevent criminal exposure and rebuild trust with the tax authorities.

Legal Foundation

Law: Income Tax Act s.239; Excise Tax Act s.327; Criminal Code s.380 (Fraud); Tax Administration Act (Québec) ss.100–106.
Jurisprudence: R. v. Jarvis (2002 SCC) — distinguished between audit and criminal investigation, confirming that once the primary purpose becomes penal, taxpayer rights under the Charter apply.

Why You Need a CPA for a Criminal Investigation Audit

When CRA initiates a Criminal Investigation, their auditors no longer act as assessors—they act as investigators. Statements can be used as evidence in court. Mackisen CPA Montreal ensures immediate protection of your rights, coordinates with tax lawyers, and manages communications with CRA to prevent escalation. We review every transaction, file, and digital record to eliminate exposure and correct compliance gaps before formal charges arise.

Learning insight: A tax investigation is not about what you owe—it’s about what CRA thinks you intended. A CPA reframes intent with facts, documents, and evidence.

What Mackisen CPA’s Criminal Audit Defense Includes

• Rapid assessment of CRA or Revenue Québec criminal inquiry letters.

• Coordination with legal counsel for privilege-protected responses.

• Forensic reconstruction of books, ledgers, and digital transaction records.

• Documentation of intent to comply and correction of identified discrepancies.

• Negotiation with CRA to revert a criminal inquiry to a civil reassessment.

Learning insight: CRA can suspect fraud when records are unclear. A CPA ensures clarity becomes your best legal defense.

Common Triggers for CRA Criminal Investigations

• Repeated false statements or omissions on returns.

• Fabricated invoices or altered sales records.

• Unreported cash sales or bank deposits.

• Use of shell companies or false suppliers.

• Aggressive tax-shelter schemes or fake charitable receipts.

Mackisen CPA Montreal performs a confidential internal audit to uncover and correct issues before CRA gathers evidence. Prevention begins with transparency.

How Mackisen CPA Manages Criminal Investigations

1. Conducts a privilege-protected forensic review of tax records and digital transactions.

2. Evaluates all correspondence from CRA’s Criminal Investigations Division.

3. Builds a defense narrative supported by accounting facts and commercial logic.

4. Works with tax lawyers to negotiate compliance agreements or voluntary disclosures.

5. Provides ongoing compliance monitoring to prevent recurrence.

Learning insight: CRA prosecutes patterns, not people. If you show consistent correction and cooperation, they return to civil enforcement.

Benefits of Professional Representation

• Protects directors and shareholders from criminal liability.

• Prevents escalation from civil to criminal status.

• Demonstrates intent to comply and correct past errors.

• Strengthens privilege through CPA-lawyer collaboration.

• Ensures Charter rights are respected throughout the investigation.

Learning insight: In a CID audit, silence and structure protect better than speed. A CPA guides every word and every document.

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Learning insight: CRA investigates intent; a CPA documents compliance. Evidence of integrity is the best defense.

Real Client Success

• A Montreal retailer avoided criminal prosecution when Mackisen CPA proved bookkeeping errors were unintentional and provided corrected filings within 14 days.

• A construction company owner had charges dropped after our forensic audit showed accurate GST/QST allocation.

• A consultant prevented file escalation by entering a voluntary-disclosure agreement managed by Mackisen CPA.

Why Mackisen CPA Montreal

With decades of investigative and forensic experience, Mackisen CPA Montreal understands how to convert a high-risk audit into a compliance resolution. Our team works under strict confidentiality, coordinating accountants, lawyers, and forensic specialists to protect your business and reputation.

Learning insight: CRA measures intent by conduct. When you act transparently through a CPA, you turn suspicion into cooperation.

Learning conclusion: Criminal audits can begin quietly and end severely. Mackisen CPA Montreal intervenes early, proving diligence, honesty, and control—transforming your audit into evidence of integrity, not intent.