CRA Tax Audit Defense 2025

Cross-matching. CRA’s algorithms now flag tax returns that deviate from industry averages or contain even minor inconsistencies. Many honest taxpayers are being reassessed for missing receipts, overstated expenses, or simple accounting errors. These audits can quickly lead to six-figure reassessments, interest, and penalties. At Mackisen CPA Auditors Montreal, we defend taxpayers against unfair CRA audits. Our CPA auditors and tax lawyers build strategic defenses that prove compliance, protect your deductions, and eliminate penalties. We don’t let CRA’s systems interpret your honesty as negligence — we restore fairness, accuracy, and peace of mind.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 152(1): Grants CRA authority to assess or reassess taxpayers but requires factual justification. Section 230(1): Obligates taxpayers to maintain adequate books and records for six years — Mackisen ensures your documentation meets CRA standards. Section 18(1)(a): Defines allowable business deductions — CRA must prove noncompliance, not assume it. Section 163(2): Imposes gross negligence penalties that Mackisen removes through documented defense. Section 220(3.1): Permits CRA to cancel penalties and interest through the Taxpayer Relief Program.
Tax Administration Act (Quebec) Revenu Québec mirrors CRA’s audit authority for provincial compliance. Mackisen manages both audits simultaneously to prevent duplicate reassessments and protect your full defense.

Key Court Decisions

Bédard v. The Queen (2022): CRA must demonstrate evidence, not assumption, before reassessing taxpayers. Thibault v. The Queen (2022): Documentation and good faith filing negate grounds for penalties. Guindon v. Canada (2015): Honest errors and professional reliance cannot be treated as fraud. Jordan v. The Queen (2009): CRA must apply procedural fairness throughout the audit process. These rulings confirm that CRA cannot penalize taxpayers without evidence or fair process.

Why CRA Targets Taxpayers for Audit

CRA’s 2025 audit model relies on data-driven red flags. Common triggers include inconsistent expense ratios, large cash transactions, home office deductions, missing T4s or T5s, or unexplained bank deposits. CRA assumes risk — Mackisen proves compliance.

Mackisen’s Audit Defense Strategy

1. Audit File Review: Examine CRA’s audit letter, identify risk areas, and verify documentation gaps. 2. Documentation Reconstruction: Rebuild missing receipts, contracts, or proof of business purpose. 3. Negotiation & Representation: Communicate directly with CRA auditors to resolve disputes before reassessment. 4. Formal Objection Filing: Submit a Notice of Objection to halt CRA’s collection and preserve taxpayer rights. 5. Penalty & Interest Relief: File under Section 220(3.1) to eliminate penalties and interest for reasonable conduct. Mackisen’s defense transforms CRA’s audit into a compliance confirmation, not a punishment.

Real Client Experience

A Montreal marketing firm was reassessed $312,000 for “unsubstantiated advertising expenses.” Mackisen provided documentation and CRA cancelled the entire reassessment. A Quebec construction company was penalized $148,000 for missing invoices. Mackisen reconstructed their books and CRA reversed every penalty.

Common Questions

Can CRA audit any taxpayer? Yes — but Mackisen ensures fairness, documentation, and proper process. Can CRA go back multiple years? Generally, three years — Mackisen enforces legal limits unless fraud is proven. Can CRA cancel penalties or interest? Absolutely — we secure relief through the Taxpayer Relief Program. Can CRA audit my business and personal accounts at once? Yes, but Mackisen restricts CRA’s scope to legitimate business activity.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leading defense team for CRA audits. Our integrated team of CPAs and tax lawyers combines audit strategy, evidence, and negotiation to protect your finances and reputation. We act fast, document thoroughly, and defend relentlessly — because no honest taxpayer should fear the system. When CRA audits your file, Mackisen audits their logic. Call Mackisen CPA Auditors Montreal today for your 2025 CRA Audit Defense Consultation. The first meeting is free, and your protection starts immediately.