Insights

Oct 25, 2025

Mackisen

CRA Unreported Income Audit 2025 — Protect Your Finances, Stop CRA Penalties, and Restore Your Credibility with Mackisen CPA

CRA’s Unreported Income Audit Division is using advanced AI algorithms to match banking, payroll, and third-party data against taxpayer filings. Any discrepancy, even a small one, can trigger a full audit. Thousands of Canadians are being reassessed for so-called “unreported income” due to missing T-slips, freelance earnings, or e-commerce transactions. These audits often result in inflated assessments, compounded interest, and 50 percent gross negligence penalties — even for honest taxpayers. At Mackisen CPA Auditors Montreal, we defend individuals, professionals, and business owners against unfair CRA unreported income allegations. Our CPA auditors and tax lawyers reconstruct income accurately, correct CRA’s assumptions, and cancel penalties under the Taxpayer Relief Program. We don’t let CRA turn data mismatches into accusations — we bring the truth back into your file.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 2(1): Requires taxpayers to report worldwide income annually. Section 15(1): Governs shareholder benefits and related-party transactions often flagged as unreported income. Section 152(4): Allows CRA to reassess up to three years, or longer in cases of alleged misrepresentation — Mackisen ensures this limit is enforced. Section 163(2): Imposes gross negligence penalties that Mackisen removes through documented good faith. Section 220(3.1): Permits CRA to cancel or reduce penalties and interest under the Taxpayer Relief Program.
Tax Administration Act (Quebec) Revenu Québec performs parallel audits on unreported income from business, rental, or investment sources. Mackisen manages both federal and provincial cases to ensure consistency and full compliance.

Key Court Decisions

Bédard v. The Queen (2022): CRA cannot rely solely on bank deposits or assumptions to prove unreported income. Thibault v. The Queen (2022): Income errors caused by omission or reliance on professional advice do not constitute negligence. Guindon v. Canada (2015): Gross negligence requires proof of deliberate concealment, not accidental oversight. Jordan v. The Queen (2009): CRA’s burden of proof applies in all reassessment and audit disputes. These rulings confirm that CRA must provide evidence, not assumptions, when alleging unreported income.

Why CRA Targets Unreported Income

CRA’s 2025 audit systems automatically flag inconsistencies between tax returns and third-party data. Common triggers include missing T4, T5, or T4A slips, cash transactions, e-commerce earnings, rental income, and cryptocurrency trading. CRA assumes concealment — Mackisen proves compliance, intent, and documentation.

Mackisen’s Unreported Income Defense Strategy

  1. Data Verification: Review CRA’s audit report and compare third-party data to actual income. 2. Documentation Reconstruction: Collect invoices, receipts, and financial records to substantiate income. 3. Negotiation & Explanation: Engage CRA auditors directly to correct inaccurate assumptions and estimated assessments. 4. Formal Objection Filing: File a Notice of Objection to suspend CRA collection and ensure impartial review. 5. Penalty & Interest Relief: Submit a Taxpayer Relief application under Section 220(3.1) for full cancellation of charges. Mackisen’s approach ensures CRA’s assumptions are replaced with verified facts.

Real Client Experience

A Montreal contractor was reassessed $168,000 for “unreported income.” Mackisen provided records of double-counted deposits and CRA withdrew the full reassessment. A Quebec consultant was fined $62,000 for unreported e-commerce income. Mackisen filed an objection and CRA cancelled all penalties within eight weeks.

Common Questions

Can CRA find unreported income automatically? Yes, but Mackisen ensures full context and proof before any reassessment is finalized. Can CRA reassess old tax years? Only within three years unless they can prove misrepresentation — Mackisen enforces that rule. Can CRA cancel penalties and interest? Absolutely, through the Taxpayer Relief Program. What if I forgot to include income on my return? Mackisen files an adjustment or voluntary disclosure to prevent penalties.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s trusted defenders against CRA unreported income allegations. Our integrated team of CPAs and tax lawyers corrects CRA’s assumptions, restores taxpayer credibility, and eliminates financial penalties. We act quickly, document thoroughly, and defend fearlessly — because mistakes don’t mean misconduct. When CRA calls your honesty into question, Mackisen answers with proof. Call Mackisen CPA Auditors Montreal today for your 2025 Unreported Income Audit Defense Consultation. The first meeting is free, and your protection starts immediately.

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