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

A CRA Reassessment or Re-Audit occurs when the Canada Revenue Agency (CRA) or Revenue Québec revisits previously assessed returns because of new information, discrepancies, or suspected misrepresentation. Unlike a standard audit, a reassessment can reopen prior years within a statutory limitation period—typically three years for individuals and CCPCs, but extended indefinitely in cases of negligence or fraud. Mackisen CPA Montreal provides expert representation to manage reassessments, defend prior filings, and reduce tax exposure through precise documentation and legal argumentation.

Legal Foundation

Law: Income Tax Act s.152(3.1)–(4); Tax Administration Act (Québec) s.1014–1017.
Jurisprudence: Collins v. The Queen (1996 TCC) — established that reassessment beyond the normal limitation period requires demonstrable misrepresentation or new facts discovered.

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

A reassessment is not a new audit—it’s a second look at your prior filings. CRA typically triggers a re-audit when new data emerges (bank information, third-party reports, informant tips, or inter-agency data exchanges). Mackisen CPA Montreal ensures that every previously filed return is re-examined for accuracy, properly defended, and supported by legal citations to avoid repeated taxation of the same income or expenses.

Learning insight: CRA re-audits history, not intent. A CPA ensures your past filings still tell a defensible story.

What Mackisen CPA’s Reassessment Defense Includes

• Full review of all prior-year notices of assessment and adjustments.

• Identification of audit triggers, including CRA risk algorithms and third-party information slips.

• Reconciliation of financial statements and tax returns to supporting ledgers.

• Legal representation letters citing ITA s.152(4) and jurisprudence protection.

• Filing of objection (Form T400A / MR-93.1) if reassessment is unjustified.

Learning insight: The 3-year clock can reset if CRA alleges misrepresentation. CPA documentation keeps that door firmly closed.

Common Triggers for CRA and ARQ Reassessments

• New data from financial institutions or T-slip corrections.

• Audit of a related entity revealing previously undisclosed income.

• Adjustments to GST/QST returns affecting income-tax filings.

• Late or amended T1135 foreign-property filings.

• ARQ data mismatches between CO-17 and TP1 filings.

Mackisen CPA Montreal identifies these triggers early, allowing you to respond before the reassessment is finalized.

How Mackisen CPA Manages Reassessments

1. Requests full CRA audit notes and supporting documentation under the Access to Information Act.

2. Reviews prior-year working papers and aligns with accounting evidence.

3. Submits a detailed CPA opinion with legal and financial analysis.

4. Negotiates with the appeals officer to resolve issues without court intervention.

5. Coordinates potential relief under s.220(3.1) for interest and penalties.

Learning insight: The best defense against reassessment is contemporaneous proof. The law rewards those who documented before they were questioned.

Benefits of Professional Representation

• Protects against reopening of additional taxation years.

• Prevents duplication of income recognition across multiple years.

• Preserves deduction entitlements and credit carry-forwards.

• Strengthens compliance file for future CRA reviews.

• Provides full legal coordination for objection or appeal if required.

Learning insight: CRA re-audits numbers; Mackisen CPA re-validates facts. Every number backed by evidence becomes audit-proof twice over.

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Learning insight: Reassessments are not punishments—they’re opportunities to prove precision. Mackisen CPA turns CRA’s second look into your strongest proof of compliance.

Real Client Success

• A Montreal professional cleared a $45,000 reassessment when Mackisen CPA demonstrated CRA’s error in year-end accrual timing.

• A retailer avoided a 5-year re-audit expansion after our CPA team cited limitation protection under ITA s.152(3.1).

• A technology firm reduced a $120,000 GST/QST reassessment to zero by reconciling intercompany invoices.

Why Mackisen CPA Montreal

Mackisen CPA Montreal combines tax litigation support, audit defense, and forensic accounting expertise to handle reassessments swiftly and effectively. We balance law and accounting to demonstrate both technical and ethical compliance.

Learning insight: CRA may reopen the past—but Mackisen CPA closes it again with proof, not promise.

Learning conclusion: The 3-year rule exists to protect honest taxpayers. Mackisen CPA Montreal ensures that once your returns are filed right, they stay closed—permanently.