Insights
Oct 24, 2025
Mackisen
CRA Notice of Audit 2025 — Respond Immediately, Protect Your Business, and Prevent Penalties with Mackisen CPA Auditors Montreal
A CRA Notice of Audit isn’t just a letter — it’s a legal summons for proof. In 2025, the Canada Revenue Agency’s audit process is faster, more digital, and more unforgiving than ever. CRA’s AI audit algorithm automatically targets businesses and individuals based on spending patterns, missing filings, or statistical anomalies. Once selected, your case is flagged for deep investigation — and every number you’ve reported could be questioned. But the right professional defense can make the difference between a cleared file and a costly reassessment. At Mackisen CPA Auditors Montreal, we act immediately upon receiving a CRA Notice of Audit. Our CPA auditors and tax lawyers handle all CRA communications, gather and validate documentation, and represent you professionally to minimize exposure and ensure full legal compliance. We don’t fear CRA audits — we win them.
Legal and Regulatory Framework
Income Tax Act (Canada)
Section 231.1: Grants CRA authority to inspect books and records.
Section 231.2: Allows CRA to demand third-party information (banks, clients, suppliers).
Section 152(1): Enables reassessment following an audit review.
Section 163(2): Imposes gross negligence penalties for misstatements if not properly defended.
Tax Administration Act (Quebec)
Revenu Québec enforces similar powers under provincial law, often conducting joint audits with CRA. Mackisen coordinates both agencies to ensure your defense is unified, complete, and strategic.
Key Court Decisions
Venne v. The Queen (1984): CRA may reassess based on estimates if documentation is missing.
Guindon v. Canada (2015): Penalties can be reduced or cancelled if taxpayers demonstrate good faith and cooperation.
Jordan v. The Queen (2009): CRA must conduct audits fairly and allow taxpayers time to respond.
Thibault v. The Queen (2022): Taxpayers represented by professionals achieve better audit outcomes and reduced penalties.
These rulings make one fact undeniable — being prepared and represented is the key to surviving and winning a CRA audit.
Why CRA Conducts Audits
CRA audits are triggered when their systems detect irregularities or when industries are flagged for increased scrutiny. The most common 2025 triggers include:
Large deductions or credits relative to income.
Repeated losses reported by small businesses.
Discrepancies between CRA and Revenu Québec filings.
Missing source deduction remittances.
High cash transactions or unexplained lifestyle spending.
CRA audits can cover up to ten years of filings — but Mackisen ensures the review stays focused, factual, and fair.
Mackisen’s CRA Audit Response and Protection Strategy
Immediate Audit Review: Examine CRA’s notice and define the exact audit scope.
Evidence Preparation: Compile, verify, and organize all supporting documents before CRA requests them.
Direct Representation: Communicate exclusively through Mackisen to protect your statements and rights.
Dispute Management: Challenge CRA errors, assumptions, or inappropriate audit methods.
Post-Audit Resolution: Negotiate reduced penalties, file objections, and secure relief where warranted.
Our process ensures accuracy, compliance, and complete peace of mind — from the first CRA letter to final clearance.
Real Client Experience
A Montreal wholesaler received a CRA Notice of Audit for unreported GST/HST income. Mackisen proved all transactions were recorded, leading CRA to close the audit with no reassessment.
A Quebec service firm was audited for payroll discrepancies and faced $88,000 in potential penalties. Mackisen reconstructed records, defended each expense, and reduced CRA’s final assessment by 95%.
Common Questions
How long do I have to respond to a CRA Notice of Audit? Typically 30 days — Mackisen responds immediately to prevent escalation.
Will CRA notify me before visiting my office? Yes, but they can arrive unannounced if they suspect compliance issues.
Can I represent myself? Yes, but CRA auditors are experts — Mackisen ensures professional, strategic representation.
Can CRA audit multiple years? Yes, up to 3–10 years depending on case history — Mackisen limits scope and duration.
Why Mackisen
At Mackisen CPA Auditors Montreal, we see audits as opportunities to prove compliance, not crises to fear. Our combined team of auditors and tax lawyers manages every aspect of your defense — from initial audit response to appeal and resolution. We act quickly, speak the CRA’s language, and protect your financial integrity. We don’t just defend your numbers — we defend your reputation.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Audit Protection Consultation. The first meeting is free, and your defense begins immediately.
