Insights
Oct 24, 2025
Mackisen
CRA Reassessment Appeal 2025 — Overturn CRA Decisions, Remove Penalties, and Restore Your Financial Rights
A CRA Reassessment can devastate a taxpayer’s finances if left unchallenged. In 2025, CRA’s audit and reassessment systems are powered by artificial intelligence that often produces automated, assumption-based calculations rather than fact-based findings. These reassessments can include massive tax adjustments, interest charges, and 50% negligence penalties — even for honest mistakes. But the good news is that every reassessment can be appealed and overturned with a strong, professional defense. At Mackisen CPA Auditors Montreal, we specialize in appealing CRA reassessments through strategic evidence presentation and legal advocacy. Our CPA auditors and tax lawyers file timely objections, reconstruct accurate documentation, and negotiate directly with CRA Appeals Officers and Tax Court representatives. We don’t just challenge CRA’s numbers — we challenge their assumptions.
Legal and Regulatory Framework
Income Tax Act (Canada)
Section 165(1): Grants taxpayers the right to file a Notice of Objection within 90 days of reassessment.
Section 166.1: Provides authority to appeal to the Tax Court of Canada if CRA denies or ignores the objection.
Section 220(3.1): Allows taxpayers to apply for penalty and interest relief under the Taxpayer Relief Program.
Section 161(1): Defines CRA’s authority to charge daily compounded interest until appeals are resolved.
Tax Administration Act (Quebec)
Revenu Québec mirrors CRA’s reassessment appeal system, allowing taxpayers to object to provincial tax adjustments simultaneously. Mackisen ensures both federal and Quebec objections are perfectly aligned to prevent double taxation.
Key Court Decisions
Venne v. The Queen (1984): Taxpayers can overturn reassessments by providing verifiable evidence and timely objections.
Guindon v. Canada (2015): CRA’s negligence penalties can be removed when taxpayers act in good faith.
Thibault v. The Queen (2022): Courts consistently rule in favor of taxpayers who provide organized, professional documentation.
Jordan v. The Queen (2009): CRA’s reassessment must be based on evidence — not speculation.
These cases confirm that CRA reassessments are defensible when handled with precision, strategy, and persistence.
Why CRA Reassesses Taxpayers
Reassessments occur when CRA questions your deductions, income, or reporting accuracy. The most common 2025 triggers include:
Missing or mismatched income slips.
Denied expenses or Input Tax Credits (ITCs).
Disallowed medical, charitable, or business deductions.
GST/HST or QST audit discrepancies.
Errors from previous CRA system recalculations.
CRA’s goal is to collect quickly — but Mackisen’s goal is to ensure you pay only what’s rightfully owed.
Mackisen’s CRA Reassessment Appeal and Defense Strategy
Reassessment Analysis: Review CRA’s letter, audit findings, and legal reasoning for flaws or omissions.
Documentation Rebuild: Gather missing receipts, contracts, or financial proof supporting your original filings.
Notice of Objection Filing: File a formal objection within 90 days to pause CRA’s collection and trigger a review.
Appeal Preparation: Prepare your case for CRA Appeals Division or Tax Court with complete financial and legal evidence.
Penalty and Interest Relief: File simultaneous relief applications under Section 220(3.1) to reduce total debt exposure.
Our defense approach combines audit precision, legal expertise, and negotiation skill — giving you a powerful advantage against CRA.
Real Client Experience
A Montreal retailer was reassessed $92,000 after CRA denied legitimate marketing expenses. Mackisen appealed and submitted full documentation — CRA reversed 100% of the reassessment.
A Quebec professional was reassessed $38,000 for “unreported income” due to CRA’s data error. Mackisen proved duplicate T-slip reporting and secured a complete cancellation within 30 days.
Common Questions
Can I appeal a CRA reassessment on my own? You can, but CRA is legally trained and aggressive — Mackisen ensures your defense is complete and persuasive.
What happens if I miss the 90-day deadline? We can request an extension of up to one year with valid justification.
Does CRA stop collections during appeal? Yes — if an objection or Tax Court appeal is filed, CRA must suspend enforcement.
Can I appeal both CRA and Revenu Québec? Yes — Mackisen handles both jurisdictions simultaneously to ensure full protection.
Why Mackisen
At Mackisen CPA Auditors Montreal, we fight every reassessment with evidence, law, and determination. Our team’s experience in CRA appeals and Tax Court representation ensures no unfair tax stands unchallenged. We protect your finances, your rights, and your future — because you deserve fairness, not fear. When CRA reassesses, Mackisen restores balance.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Reassessment Appeal Consultation. The first meeting is free, and your protection begins immediately.
