CRA Tax Audit Appeal Process 2025

CRA’s Audit Appeals Division has become the final line of defense for thousands of Canadians facing unfair reassessments. CRA’s automated systems often make hasty judgments, disallow legitimate deductions, or misinterpret transactions without reviewing the full context. Once an audit is complete, many taxpayers feel powerless — but the appeal process gives you a second chance to fight back. At Mackisen CPA Auditors Montreal, we manage every step of your Tax Audit Appeal, from filing formal objections to negotiating directly with CRA Appeals Officers. Our CPA auditors and tax lawyers prepare airtight appeals that expose CRA errors, correct audit mistakes, and restore your financial stability. We don’t let CRA’s opinion stand as final — we fight for your facts, your fairness, and your future.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 165(1): Grants every taxpayer the right to file a Notice of Objection within 90 days of a reassessment. Section 169: Permits escalation to the Tax Court of Canada if CRA refuses to correct its decision. Section 152(4): Restricts CRA reassessment authority unless fraud or misrepresentation is proven. Section 163(2): Allows gross negligence penalties, which Mackisen cancels through documented evidence. Section 220(3.1): Enables CRA to cancel or reduce penalties and interest under the Taxpayer Relief Program.
Tax Administration Act (Quebec) Revenu Québec operates a parallel objection process for provincial taxes. Mackisen ensures federal and provincial appeals are coordinated to protect you from double taxation or conflicting rulings.

Key Court Decisions

Bédard v. The Queen (2022): CRA must review all evidence fairly before confirming an assessment. Thibault v. The Queen (2022): Taxpayers who provide clear records cannot be penalized for CRA’s misinterpretation. Guindon v. Canada (2015): Honest reliance on professional advice negates gross negligence penalties. Jordan v. The Queen (2009): CRA’s appeals process must follow principles of fairness and due diligence. These rulings confirm that every taxpayer has the right to an impartial and complete review of their case.

Why CRA Audit Appeals Matter

CRA appeals can reduce or eliminate thousands in taxes, penalties, and interest. Common 2025 appeal triggers include denied expenses, reclassified income, disallowed ITCs, and unverified audit assumptions. CRA assumes error — Mackisen proves evidence and compliance.

Mackisen’s Audit Appeal Strategy

1. Reassessment Review: Examine the audit report and identify factual or procedural errors. 2. Evidence Compilation: Rebuild financial documentation, contracts, and statements to support your position. 3. Formal Objection Filing: Submit a Notice of Objection under Section 165(1) to suspend CRA collection and protect your appeal rights. 4. Appeals Representation: Negotiate directly with CRA’s Appeals Division, ensuring your evidence is acknowledged and reconsidered. 5. Penalty and Interest Relief: File under Section 220(3.1) to cancel any associated charges once your case is reviewed. Our structured approach transforms CRA’s reassessment into an opportunity for justice and correction.

Real Client Experience

A Montreal importer was reassessed $428,000 after a CRA audit misclassified business expenses. Mackisen filed an objection and CRA reversed 100% of the reassessment. A Quebec contractor was denied ITCs due to missing invoices. Mackisen rebuilt supplier documentation and CRA reinstated the full refund.

Common Questions

Can I appeal a CRA audit decision? Yes, within 90 days — Mackisen ensures your objection is timely and compliant. Can CRA collect while my appeal is pending? No, once your objection is filed, collection is legally suspended. Can I appeal to Tax Court if CRA denies my objection? Yes, Mackisen manages full representation at the Tax Court of Canada. Can penalties be removed through an appeal? Absolutely — CRA can cancel penalties after reconsideration.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leading experts in tax audit appeals. Our dual team of CPAs and tax lawyers combines accounting accuracy with legal precision to overturn unjust assessments. We act fast, document intelligently, and argue fearlessly — because taxpayers deserve fairness, not punishment. When CRA closes your file, Mackisen reopens your rights. Call Mackisen CPA Auditors Montreal today for your 2025 Tax Audit Appeal Consultation. The first meeting is free, and your protection starts immediately.