CRA Reassessment Audit 2025 — Reverse CRA Errors, Defend Your Rights, and Protect Your Business

CRA’s Reassessment Division is issuing more audit-based adjustments than ever before. With artificial intelligence driving data-matching and industry benchmarking, many honest taxpayers are being unfairly reassessed for income discrepancies, expense reclassification, or incomplete records. CRA’s automated approach often leads to inaccurate assumptions that inflate tax liability and trigger steep penalties. At Mackisen CPA Auditors Montreal, we challenge every unfair reassessment with precision and legal expertise. Our CPA auditors and tax lawyers prepare factual defenses that expose CRA’s errors, eliminate penalties, and restore your financial integrity. We don’t let CRA’s systems dictate your truth — we defend it with law, documentation, and strategy.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 152(4): Allows CRA to reassess a taxpayer within three years of the original assessment, unless misrepresentation or fraud is proven. Section 163(2): Permits gross negligence penalties, which Mackisen cancels through documented good faith and compliance evidence. Section 165(1): Grants taxpayers the right to file a Notice of Objection to dispute a reassessment. Section 169: Provides the right to appeal to the Tax Court of Canada when CRA refuses correction. Section 220(3.1): Enables CRA to cancel or reduce penalties and interest through the Taxpayer Relief Program.
Tax Administration Act (Quebec) Revenu Québec mirrors CRA’s reassessment process, often following the same audit data. Mackisen coordinates both federal and provincial reassessment defenses to ensure unified and consistent results.

Key Court Decisions

Bédard v. The Queen (2022): CRA must base reassessments on verifiable evidence, not assumptions. Thibault v. The Queen (2022): Audited taxpayers with valid records cannot be penalized for auditor interpretation. Guindon v. Canada (2015): Penalties require proof of intent to mislead, not simple error. Jordan v. The Queen (2009): CRA’s reassessment process must follow principles of fairness and transparency. These cases prove that CRA’s reassessment power has limits — and Mackisen ensures they are respected.

Why CRA Reassesses

CRA’s reassessment system flags files that show statistical anomalies or missing supporting evidence. Common triggers include home office expenses, vehicle deductions, shareholder loans, foreign property disclosures, or mismatched income slips. CRA assumes misrepresentation — Mackisen proves accuracy and documentation.

Mackisen’s Reassessment Defense Strategy

1. File Analysis: Examine CRA’s reassessment letter and audit notes to identify procedural or factual flaws. 2. Documentation Reconstruction: Gather receipts, invoices, contracts, and reports that substantiate your filings. 3. Objection and Appeal: File a Notice of Objection within 90 days to suspend collection and trigger a fair review. 4. Legal Representation: Negotiate directly with CRA Appeals Officers to reduce or cancel reassessments. 5. Penalty and Interest Relief: File under Section 220(3.1) to cancel penalties once good faith is proven. Mackisen’s method transforms CRA’s assumptions into facts that favor your compliance.

Real Client Experience

A Montreal consulting firm was reassessed $312,000 for “unreported income.” Mackisen identified data duplication and CRA reversed the entire amount. A Quebec property investor was fined $94,000 for “misclassified capital gains.” Mackisen defended the classification and CRA dropped all penalties.

Common Questions

Can CRA reassess multiple years at once? Yes, but only within three years unless fraud is alleged — Mackisen ensures CRA respects that limit. Can CRA charge penalties during reassessment? Yes, but Mackisen eliminates them through Taxpayer Relief. Can I appeal CRA’s reassessment decision? Absolutely — Mackisen manages all objections and Tax Court appeals. Can CRA reassess after an audit is closed? Only under new evidence — Mackisen prevents repeated reassessments on resolved issues.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leading defenders against CRA reassessments. Our team of CPAs and tax lawyers merges technical tax expertise with strategic negotiation to overturn inaccurate reassessments and restore fairness. We act fast, argue with evidence, and defend fearlessly — because you deserve truth, not assumption. When CRA reassesses, Mackisen restores balance. Call Mackisen CPA Auditors Montreal today for your 2025 CRA Reassessment Defense Consultation. The first meeting is free, and your protection starts immediately.