CRA Reassessment / Re-Audit — Montreal CPA Firm Near You: Manage the 3-Year Clock

A CRA Reassessment or Re-Audit is a serious stage of tax administration that occurs after your initial Notice of Assessment (NOA) has been issued. It means the Canada Revenue Agency (CRA) or Revenue Québec has found new information, discrepancies, or alleged misrepresentations and now intends to adjust your prior tax filings. Managing this process within the strict 3-year reassessment period is essential to protect your rights, avoid penalties, and preserve appeal opportunities. Mackisen CPA Montreal offers specialized representation to handle every step of the reassessment process.

Legal Foundation

Law: Income Tax Act s.152(3.1) and s.231.1 — authorizes CRA to reassess within three years of the original NOA or beyond that period if misrepresentation or fraud is alleged.
Jurisprudence: Hickman Motors Ltd. v. Canada (1997 SCC) — establishes that reassessments are presumed valid but can be successfully challenged when documentation and evidence clearly support the taxpayer’s original filing.

Why You Need a CPA for a Reassessment or Re-Audit

A reassessment is not a routine review—it is a formal government action that changes your tax outcome. Most reassessments arise from CRA audit findings, third-party information, or automatic system comparisons. Without CPA representation, taxpayers often miss crucial response deadlines or submit incomplete documentation, which can permanently affect their appeal rights.

Mackisen CPA Montreal ensures that all responses, appeals, and objections are timely, accurate, and strategically built on both tax law and accounting standards.

Learning insight: CRA reassessments operate under a strict burden of proof—you must disprove the reassessment, not the other way around. Professional representation converts uncertainty into structured defense.

What Mackisen CPA’s Reassessment Defense Includes

• Full review of CRA’s reassessment notice and supporting audit file.

• Legal and factual analysis of every proposed adjustment.

• Reconstruction of accounting records to align with CRA’s assumptions.

• Preparation of a CPA objection letter referencing supporting evidence and relevant jurisprudence.

• Representation in discussions or conferences with CRA appeals officers.

Learning insight: The right objection letter can close a reassessment before it escalates to the Tax Court of Canada. Clarity and evidence are the CPA’s best tools.

Common Triggers for CRA Reassessments

• Late or missing documentation during initial audit.

• Undeclared income identified through third-party data.

• Reclassification of personal expenses as business costs.

• Denial of input tax credits or capital-cost allowances.

• Disallowed deductions for management fees or interest charges.

Mackisen CPA Montreal proactively identifies each trigger and addresses it with proper documentation, factual clarification, and legal precedent.

How Mackisen CPA Manages the Reassessment Process

1. Performs a detailed diagnostic review of CRA’s assumptions and evidence.

2. Builds a line-by-line rebuttal cross-referenced with the Income Tax Act.

3. Files Notice of Objection (Form T400A or TP-1039) within the statutory deadline.

4. Engages directly with CRA Appeals or Revenue Québec’s Direction des oppositions.

5. Prepares litigation-ready files if the case proceeds to the Tax Court of Canada.

Learning insight: The 90-day objection window is non-negotiable. A late or incomplete objection can cost you the right to appeal. Mackisen CPA ensures full protection of procedural rights.

Benefits of Professional Reassessment Representation

• Stops interest accumulation on disputed balances.

• Prevents additional penalties or extended reassessment periods.

• Provides complete documentation and case-law support.

• Enhances credibility before CRA Appeals.

• Positions you for success if the dispute escalates to court.

Learning insight: In tax defense, professionalism equals protection. A structured CPA response shows the government that your compliance position is deliberate and defensible.

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Learning insight: A reassessment is not a verdict—it’s a challenge. Mackisen CPA transforms it into an opportunity to strengthen your compliance record and recover your tax position.

Real Client Success

• A manufacturing firm overturned a $96,000 reassessment after Mackisen CPA reconstructed CCA schedules proving depreciation eligibility.

• A contractor avoided a gross-negligence penalty after our objection letter cited procedural errors in CRA’s evidence collection.

• An IT consultant recovered $14,500 in denied GST/QST credits following our successful appeals submission.

Why Mackisen CPA Montreal

Mackisen CPA’s audit and tax-defense division has more than 35 years of combined experience managing complex reassessments and re-audits. Our direct relationships with CRA Appeals and Revenue Québec allow us to negotiate efficient, evidence-based outcomes for individuals and corporations alike.

Learning insight: The CRA’s reassessment power is broad—but not absolute. The better your documentation and CPA representation, the more control you retain over the outcome.

Learning conclusion: A CRA Reassessment is your chance to defend your numbers, your rights, and your reputation. With Mackisen CPA Montreal, your response becomes your strongest legal and financial advantage.