CRA Pre-Assessment Review (Second Request) 2025 — Avoid Refund Delays, Strengthen Your Evidence, and Stop

When the CRA contacts you again for more documents after your first response, it’s a warning sign: your file has moved from routine verification to heightened review. In 2025, CRA’s AI-driven pre-assessment system automatically re-checks claims that remain unclear — often freezing refunds or triggering full audits. A “second request” means CRA wants proof that is airtight, complete, and consistent across every page of your return. One missing receipt or mismatched number can now delay refunds for months or escalate into a full reassessment.

At Mackisen CPA Auditors Montreal, we treat second CRA requests as strategic turning points. Our tax lawyers and CPA auditors rebuild the file from the ground up — verifying every figure, cross-referencing T-slips, and submitting evidence in the exact order CRA examiners require. We don’t just reply; we close the file cleanly before it becomes an audit.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 152(1): Authorizes CRA to review returns before assessment.

• Section 231.1 & 231.2: Empowers CRA to demand books, records, and third-party confirmation.

• Section 162(1): Applies penalties for incomplete or misleading submissions.

• Section 163(2): Allows 50 % gross-negligence penalties if the second review reveals omissions.

Tax Administration Act (Quebec)
Revenu Québec can issue simultaneous second requests for credits or deductions claimed on the provincial side, and discrepancies between the two agencies can delay both refunds.

Mackisen ensures both CRA and Revenu Québec files mirror each other — preventing double reviews and preserving compliance.

Key Court Decisions

Guindon v. Canada (2015): Inaccurate or careless responses can attract enforceable penalties.
Venne v. The Queen (1984): Failure to keep verifiable records allows CRA to reassess based on estimates.
Leblanc v. The Queen (2019): Taxpayers must prove every claim with contemporaneous documentation.

These precedents confirm that proof, not intent, decides CRA outcomes.

Why Second Requests Happen

A second review means CRA wasn’t satisfied with your first submission or found new inconsistencies through automated cross-matching. Frequent triggers include:

• Receipts that don’t match totals claimed.

• Missing third-party verification (medical, tuition, or childcare).

• Home-office or employment expenses lacking employer T2200 forms.

• Charitable donation slips from non-registered charities.

• Differences between CRA and Revenu Québec amounts.

Ignoring or mishandling this stage almost guarantees a full audit.

Mackisen’s Second-Request Audit-Prevention Strategy

1. Risk Assessment: Identify CRA’s underlying concern behind the additional request.

2. Evidence Reconstruction: Re-create missing documentation with supplier, employer, or financial-institution confirmation.

3. Cross-Jurisdiction Reconciliation: Match CRA and Revenu Québec data line-by-line.

4. Legal Submission Package: Prepare a professional binder or digital file meeting CRA’s audit-ready format.

5. Follow-Up and Resolution: Confirm receipt, monitor processing, and obtain written clearance of the review.

Our process turns reactive panic into proactive control.

Real Client Experience

A Montreal teacher received a second CRA request for education credits. Mackisen recompiled receipts, verified the institution’s eligibility, and achieved full refund release in 12 days.
A construction contractor was re-queried for vehicle expenses. Mackisen provided reconstructed mileage logs and vendor invoices — CRA closed the review without reassessment.

Common Questions

Is a second request an audit? Not yet—but it’s the final stage before one. Mackisen stops it there.
How long do I have to respond? Usually 15–30 days. We ensure delivery and CRA confirmation before deadlines.
Can I email or upload documents? Yes — we use CRA’s secure portal and track every submission.
What if I can’t find missing paperwork? We rebuild proof from bank records, contracts, or supplier confirmations.

Why Mackisen

At Mackisen CPA Auditors Montreal, we don’t just manage CRA correspondence — we eliminate it. Our professionals prepare second-review responses that are factual, complete, and legally bulletproof, preventing reassessment and safeguarding your refund.

We combine speed, accuracy, and empathy — because when CRA asks twice, you need one perfect answer.

Call Mackisen CPA Auditors Montreal today for your 2025 CRA Second Review Consultation. The first meeting is free, and your protection starts immediately.