CRA Notice of Assessment Review 2025 — Understand, Challenge, and Correct CRA Errors with Mackisen CPA

In 2025, CRA’s Notice of Assessment (NOA) system has become almost entirely automated, issuing millions of electronic assessments each year without manual verification. While automation speeds up processing, it also increases mistakes — from missing credits and misapplied payments to unexplained balance due notices. Many Canadians assume a CRA Notice of Assessment is final when, in reality, it may contain significant errors. At Mackisen CPA Auditors Montreal, we analyze your Notice of Assessment line by line, identify every discrepancy, and file formal objections or adjustments to correct CRA’s mistakes. Our CPA auditors and tax lawyers ensure you pay only what’s accurate — nothing more. We don’t let CRA’s systems override your rights — we restore fairness through facts and evidence.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 152(1): Authorizes CRA to issue a Notice of Assessment after processing a tax return.

• Section 152(4): Governs CRA’s reassessment powers within three years from the original assessment date.

• Section 165(1): Grants every taxpayer the right to file a Notice of Objection within 90 days to dispute an assessment.

• Section 220(3.1): Permits CRA to cancel or reduce penalties and interest under the Taxpayer Relief Program.

• Section 152(8): States that the Notice of Assessment is binding unless successfully objected to — Mackisen ensures that objection is properly filed.
  Tax Administration Act (Quebec)
  Revenu Québec issues its own assessment notices for provincial taxes. Mackisen synchronizes both reviews to ensure consistency across jurisdictions.

Key Court Decisions

Bédard v. The Queen (2022): CRA assessments must reflect accurate taxpayer data and cannot be presumed correct without evidence.
Thibault v. The Queen (2022): Taxpayers have the right to challenge automated CRA assessments and request human review.
Guindon v. Canada (2015): Penalties for alleged false statements require proof of intent, not assumption.
Jordan v. The Queen (2009): CRA’s duty of procedural fairness applies to all assessments and reassessments.
These decisions confirm that CRA’s Notices of Assessment are not infallible and can be corrected through proper representation.

Why CRA Notices Contain Errors

CRA’s automated system processes millions of returns with limited manual oversight. Common 2025 NOA issues include:

• Missing RRSP, tuition, or medical credits.

• Double-counted income from duplicate slips.

• Misallocated payments or refunds.

• Incorrect penalty or interest calculations.

• Provincial-federal mismatch in tax credits or transfers.
  CRA assumes accuracy — Mackisen proves otherwise.

Mackisen’s Notice of Assessment Defense Strategy

1. Assessment Review: Examine every line of your NOA for calculation or data entry errors.

2. Supporting Documentation: Compare CRA’s figures with tax slips, receipts, and prior filings.

3. Formal Objection Filing: Submit a Notice of Objection under Section 165(1) to dispute errors within 90 days.

4. Negotiation & Resolution: Engage directly with CRA appeals officers to correct or amend the assessment.

5. Penalty & Interest Relief: File under Section 220(3.1) to eliminate any resulting penalties or interest.
   Our process ensures your Notice of Assessment truly reflects the law — not a computer error.

Real Client Experience

A Montreal teacher received a $28,000 “balance due” because CRA missed her RRSP deduction. Mackisen filed an objection and CRA reversed the full balance.
A Quebec consultant was reassessed for duplicate income. Mackisen provided documentation and CRA issued a full correction within 30 days.

Common Questions

Is a Notice of Assessment final? No — Mackisen can file an objection within 90 days to review and correct it.
Can CRA make mistakes on assessments? Yes — automated assessments often omit credits or misapply payments.
What if I miss the objection deadline? Mackisen files an extension under Section 166.1 to reopen your case.
Can CRA remove penalties from errors? Absolutely — Mackisen secures full relief under the Taxpayer Relief Program.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s trusted advocates for correcting CRA assessment errors. Our integrated team of accountants and tax lawyers ensures every assessment you receive is verified, fair, and compliant. We act fast, argue firmly, and win consistently — because taxpayers deserve accuracy, not automation. When CRA assesses you, Mackisen reassesses their math.
Call Mackisen CPA Auditors Montreal today for your 2025 Notice of Assessment Review Consultation. The first meeting is free, and your protection starts immediately.