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

A CRA Criminal Investigation Division (CID) Audit is the most serious stage of tax enforcement in Canada. When the CRA suspects deliberate tax evasion, fraud, or falsified records, the file transitions from a civil audit to a criminal investigation. At this point, the objective is no longer to assess tax—it’s to prove guilt. Mackisen CPA Montreal provides immediate CPA-led forensic defense, safeguarding your rights, reconstructing financial evidence, and working closely with legal counsel to prevent criminal referral and prosecution.

Legal Foundation

Law: Income Tax Act s.239 (tax evasion and false statements); Criminal Code s.380 (fraud); Tax Administration Act (Québec) ss.100–106.
Jurisprudence: R. v. Jarvis (2002 SCC) — established the dividing line between civil audit and criminal investigation, confirming taxpayer rights to silence and Charter protections once criminal intent is suspected.

Why You Need a CPA During a CRA Criminal Investigation

Once CRA’s Criminal Investigations Division is involved, every word, document, or omission becomes potential evidence. Ordinary audit cooperation no longer applies. A CPA ensures that communications remain factual, compliant, and legally safe. Mackisen CPA Montreal coordinates forensic accounting, privilege analysis, and defense strategy alongside tax lawyers to contain the situation before it escalates.

Learning insight: In a criminal tax investigation, silence is protection—evidence is strategy. CPA defense builds the evidence before CRA builds the case.

What Mackisen CPA’s CID Defense Strategy Includes

• Immediate forensic review of all CRA audit correspondence and seizure records.

• Reconstruction of transactions and ledgers to prove absence of intent or negligence.

• Coordination with legal counsel for Charter of Rights protection under s.7 and s.8.

• Preparation of CPA-certified financial statements demonstrating transparency and reasonableness.

• Negotiation with CRA Enforcement Branch for alternative resolutions before charges are laid.

Learning insight: CRA proves intent through omission. A CPA proves good faith through documentation.

Common Triggers for CRA Criminal Investigations

• Discovery of false invoices, duplicate expenses, or undisclosed offshore accounts.

• Prior civil audit that uncovers evidence suggesting deliberate misrepresentation.

• Anonymous tips, whistleblowers, or former employees providing information.

• Unreported cash sales or phantom deductions linked to falsified invoices.

• Failure to respond to audit requests or production orders (ITA s.231.2).

Mackisen CPA Montreal’s early intervention often prevents civil audits from becoming criminal investigations.

How Mackisen CPA Manages CID Investigations

1. Reviews every CRA audit step for procedural breaches of the Jarvis threshold.

2. Prepares forensic accounting reports demonstrating commercial reality.

3. Interfaces directly with legal counsel to ensure privilege and defense coordination.

4. Compiles CRA-compliant evidence binders showing full disclosure and lack of intent.

5. Negotiates voluntary compliance measures or deferred-assessment settlements.

Learning insight: The best defense against criminal referral is a complete, coherent financial story. CPA-led forensics make that story credible.

Benefits of Professional Representation

• Prevents criminal referral by demonstrating compliance and transparency.

• Establishes CPA–lawyer privilege to protect sensitive records.

• Minimizes penalties and legal exposure through early intervention.

• Provides full reconstruction of accounting systems for CRA verification.

• Maintains business continuity while investigations proceed.

Learning insight: CRA looks for concealment. A CPA proves compliance.

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Learning insight: When CRA sees intent, we show integrity. A CPA gives your numbers a defense lawyer’s backbone.

Real Client Success

• A Montreal tech entrepreneur avoided criminal referral after Mackisen CPA demonstrated clerical error, not evasion, in expense reporting.

• A construction company owner cleared $450,000 of alleged unreported sales when our forensic team rebuilt digital POS data.

• A professional consultant under CRA CID review avoided prosecution after Mackisen CPA prepared an audit-trail narrative proving transparency.

Why Mackisen CPA Montreal

Mackisen CPA Montreal specializes in high-stakes audits and investigations where legal exposure is personal. Our forensic accountants, tax-law specialists, and CPA auditors act as your compliance shield—proving diligence, transparency, and good faith at every stage.

Learning insight: CRA investigators assume intent; we replace that assumption with verified accounting truth.

Learning conclusion: CRA’s CID process turns mistakes into accusations. Mackisen CPA Montreal turns accusations into evidence—and evidence into exoneration.