CRA Tax Audit Defense 2025 — Stop Reassessments, Eliminate Penalties, and Protect Your Business

A CRA tax audit can change everything — your business operations, your cash flow, and even your reputation. In 2025, CRA’s audit process is powered by data-matching algorithms that detect even the smallest inconsistencies in tax filings, payroll, or GST/HST records. Once flagged, auditors can demand years of financial data, issue reassessments, and apply penalties that double your liability overnight. But a CRA audit doesn’t have to end in disaster. At Mackisen CPA Auditors Montreal, we protect individuals and businesses from audit overreach. Our CPA auditors and tax lawyers handle every aspect of your defense — from preparing documents and responding to CRA officers, to negotiating settlements and filing objections. We don’t let CRA control the narrative — we take control for you.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 231.1: Authorizes CRA to examine books, records, and property for tax verification.

• Section 231.2: Allows CRA to demand third-party information (banks, clients, or suppliers).

• Section 152(4): Gives CRA reassessment power — but only within legal timelines.

• Section 163(2): Defines penalties for gross negligence, which can be challenged with proper representation.
  Tax Administration Act (Quebec)
  Revenu Québec conducts coordinated audits for payroll, QST, and provincial tax compliance. Mackisen ensures both agencies are managed strategically under one unified defense plan.

Key Court Decisions

Venne v. The Queen (1984): CRA must use evidence, not estimation, when reassessing income.
Guindon v. Canada (2015): Penalties must be fair and proportional — hardship and good faith matter.
Bédard v. The Queen (2022): Professional defense significantly increases audit success rates.
Jordan v. The Queen (2009): CRA’s audit process must respect procedural fairness and taxpayer rights.
These rulings prove that CRA audits can be fought — and won — with expertise, documentation, and strategy.

Why CRA Audits Are Increasing in 2025

CRA is investing heavily in AI-powered audit systems to catch under-reporting and compliance errors. Common audit triggers include:

• Large or unusual deductions or credits.

• Mismatched T4, T5, or GST/HST filings.

• Consistent business losses over multiple years.

• Discrepancies between declared income and lifestyle spending.

• Random selection under CRA’s risk profiling system.
  With Mackisen, you’ll never face CRA alone — we prepare, defend, and protect at every step.

Mackisen’s CRA Tax Audit Defense Strategy

1. Audit Review: Assess CRA’s notice and identify what information they’re legally entitled to.

2. Document Reconstruction: Rebuild missing receipts, records, and ledgers before CRA reviews your file.

3. Direct Representation: Communicate exclusively through Mackisen to prevent misstatements or over-disclosure.

4. Reassessment Defense: Challenge CRA’s assumptions with legal precedents and factual evidence.

5. Appeal and Relief Filing: Submit formal objections and relief applications for penalty and interest reduction.
   Our team combines forensic accounting and legal defense to protect you from CRA’s aggressive collection tactics.

Real Client Experience

A Montreal entrepreneur faced a $118,000 CRA reassessment after an audit claimed “unreported income.” Mackisen proved CRA’s calculation errors and secured full reversal within eight weeks.
A Quebec construction firm was audited for payroll and GST discrepancies totaling $240,000. Mackisen defended the file and reduced the final balance to $17,000.

Common Questions

How far back can CRA audit me? Typically 3 years, but up to 10 if CRA alleges negligence or misrepresentation.
Can CRA audit both personal and business taxes? Yes, and they often do — Mackisen protects you under both.
Should I speak to CRA directly? No — every word matters. Let Mackisen manage communication professionally.
Can I appeal CRA’s audit results? Absolutely. We file objections, appeals, and relief requests to reverse unfair reassessments.

Why Mackisen

At Mackisen CPA Auditors Montreal, we transform CRA audits from threats into opportunities for justice. Our firm has decades of experience in tax defense, combining financial precision and legal authority to protect what you’ve built. We act quickly, think strategically, and fight relentlessly — because the CRA may audit your finances, but they’ll never audit your determination when Mackisen is by your side.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Audit Defense Consultation. The first meeting is free, and your protection begins immediately.