Insights

Oct 25, 2025

Mackisen

CRA Small Business Tax Planning 2025 — Save Smarter, Reduce Tax, and Protect Your Business with Mackisen CPA

CRA’s corporate tax environment is evolving fast, and small business owners can no longer rely on outdated tax strategies. New rules around passive income, income splitting, and capital gains are catching business owners off guard, leading to higher taxes and CRA audits. Without a proactive tax plan, many entrepreneurs are paying far more than they should. At Mackisen CPA Auditors Montreal, we help small business owners legally reduce taxes, strengthen compliance, and protect their corporate income. Our CPA auditors and tax lawyers design intelligent, CRA-approved strategies that maximize savings while keeping your business safe from reassessment. We don’t just file returns — we build long-term tax resilience.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 125(1): Provides the Small Business Deduction (SBD) for Canadian-controlled private corporations (CCPCs) on active business income. Section 18(1)(a): Defines deductible business expenses used to earn income. Section 67: Ensures all expenses claimed are reasonable and justified. Section 82(1): Outlines dividend income reporting and tax credit mechanisms. Section 220(3.1): Permits CRA to cancel or reduce penalties through the Taxpayer Relief Program when small businesses face genuine hardship.
Tax Administration Act (Quebec) Revenu Québec applies provincial corporate tax and SBD rules. Mackisen ensures your federal and provincial filings work together for maximum efficiency.

Key Court Decisions

Bédard v. The Queen (2022): CRA must respect legitimate corporate structures that achieve tax savings within the law. Thibault v. The Queen (2022): Income splitting and management fees are valid when supported by commercial purpose. Guindon v. Canada (2015): Taxpayers cannot be penalized for relying on qualified professional advice. Jordan v. The Queen (2009): CRA cannot impose penalties based on assumptions rather than verified evidence. These rulings confirm that smart planning, transparency, and documentation are the foundation of tax protection.

Why Small Business Tax Planning Matters

In 2025, CRA is targeting CCPCs with high retained earnings, related-party transactions, and passive investments. Common audit triggers include multiple corporations sharing ownership, unreported shareholder loans, or unstructured dividend withdrawals. Without strategic planning, even profitable companies lose eligibility for the SBD and face unnecessary taxes. CRA assumes complexity equals risk — Mackisen turns it into opportunity.

Mackisen’s Small Business Tax Strategy

  1. Corporate Structure Optimization: Design holding, operating, and investment structures that legally defer and reduce tax. 2. Income Allocation: Implement family compensation plans and dividend strategies within CRA’s income-splitting rules. 3. Expense Planning: Identify deductible expenses and ensure full CRA-compliant documentation. 4. Capital Gains Management: Prepare exit and succession plans to qualify for the Lifetime Capital Gains Exemption (LCGE). 5. Ongoing Compliance: Conduct quarterly tax reviews to stay audit-proof and ensure sustainable savings. Mackisen’s system ensures your business grows efficiently while remaining fully compliant.

Real Client Experience

A Montreal tech firm reduced its annual tax bill by $214,000 after Mackisen restructured its compensation plan. A Quebec manufacturer regained its Small Business Deduction after CRA had previously denied it. Mackisen’s strategic defense reversed the ruling in full.

Common Questions

Can I pay myself in dividends instead of salary? Yes, but Mackisen determines the most tax-efficient mix based on your income and corporate structure. Can CRA deny my Small Business Deduction? Only if your business is not a CCPC — Mackisen ensures your eligibility. Can I income split with my spouse or children? Yes, within the current CRA Tax on Split Income (TOSI) framework. Can I qualify for the Lifetime Capital Gains Exemption when selling my company? Absolutely — Mackisen ensures your shares meet the active business test.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s most trusted advisors in small business tax planning. Our integrated team of CPAs and tax lawyers builds proactive strategies that minimize tax, prevent audits, and maximize growth. We act early, plan precisely, and defend thoroughly — because small businesses deserve big tax advantages. When CRA audits your structure, Mackisen audits their fairness. Call Mackisen CPA Auditors Montreal today for your 2025 Small Business Tax Planning Consultation. The first meeting is free, and your strategy starts immediately.

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