Received A CRA Notice Of Reassessment 2025

Nothing unnerves taxpayers more than opening a CRA Notice of Reassessment. It’s the document that can transform a peaceful tax season into months of financial stress. In 2025, the CRA’s automated audit and reassessment systems are more aggressive than ever—cross-verifying every return with employer filings, banking data, and foreign income disclosures. Even a small discrepancy can result in a reassessment, interest, and penalties that compound daily.

A reassessment doesn’t always mean you’re wrong—but it does mean CRA believes you owe more. Without professional representation, many Canadians accept inflated or incorrect reassessments, losing thousands in overpaid tax. Timing is critical: you only have 90 days from the date on your notice to file a formal objection.

At Mackisen CPA Auditors Montreal, we act immediately to protect your rights. Our team of CPA auditors and tax lawyers reviews every line of your reassessment, identifies CRA’s errors, and builds a precise defense. We handle all correspondence with CRA or Revenu Québec, ensuring your case is resolved quickly, fairly, and professionally.

Legal and Regulatory Framework

Income Tax Act (Canada)
Section 152(4): Allows CRA to issue reassessments within 3 years (10 years for suspected misrepresentation).
Section 165(1): Grants taxpayers 90 days to file a Notice of Objection after receiving a reassessment.
Section 166.1: Outlines appeal procedures to the Tax Court of Canada if an objection is denied.
Section 161(1): Applies daily compounded interest on unpaid reassessed balances.

Tax Administration Act (Quebec)
Gives Revenu Québec similar reassessment powers, requiring parallel objections for provincial issues.

Mackisen ensures every reassessment is reviewed under both CRA and Quebec law, guaranteeing synchronized filings and airtight legal compliance.

Key Court Decisions

Guindon v. Canada (2015): CRA penalties remain enforceable even if taxpayers claim oversight or misunderstanding.
Venne v. The Queen (1984): Failure to object or appeal within deadlines makes reassessments legally binding.
Jordan v. The Queen (2009): CRA is entitled to interest until the reassessment is paid or overturned.

These rulings highlight the urgency of acting quickly and strategically when responding to a reassessment.

Why a Notice of Reassessment Matters

A CRA reassessment means the government has changed your tax return—typically increasing the amount of tax owed. Common reasons include:

• Unreported income (T4, T5, or rental income discrepancies)

• Denied deductions or expenses (business, vehicle, or home office claims)

• Adjusted RRSP or FHSA contributions

• Incorrect or missing foreign income reporting

• Mismatched information between CRA and Revenu Québec returns

Even if you disagree with the reassessment, CRA will continue to collect interest until the issue is resolved. Acting quickly and professionally is your only protection.

Mackisen’s Reassessment Defense and Resolution Strategy

1. Reassessment Review: Examine the CRA’s calculations, data sources, and rationale line-by-line.

2. Evidence Preparation: Gather and verify supporting documentation for all disputed items.

3. Formal Objection Filing: Submit a detailed Notice of Objection within 90 days to pause collection actions.

4. Negotiation and Representation: Communicate with CRA auditors and appeals officers to resolve discrepancies.

5. Appeal and Final Resolution: If necessary, escalate to the Tax Court of Canada or Revenu Québec’s appeal division.

Every Mackisen case is handled with legal precision and documented accuracy—protecting your rights and minimizing your liability.

Real Client Experience

A Montreal professional was reassessed for $38,000 after CRA disallowed moving expenses. Mackisen presented documentation proving eligibility and reversed the reassessment in full.
A small business owner received a reassessment for $92,000 due to unreported income. Mackisen uncovered CRA’s duplication error, filed an objection, and reduced the amount owed to $4,800.

Common Questions

What is a Notice of Reassessment? It’s CRA’s formal correction of your original return, often increasing tax owed.
How long do I have to respond? You have 90 days from the notice date to file a formal objection. Mackisen files it for you immediately.
Do I have to pay before appealing? No—you can pause payment collection while your objection is under review.
Can CRA reassess old tax years? Normally up to 3 years, but up to 10 if CRA alleges misrepresentation. Mackisen ensures deadlines are strictly enforced.

Why Mackisen

At Mackisen CPA Auditors Montreal, we protect taxpayers from unfair reassessments. Our experts know CRA procedures better than most auditors do—because we’ve been on both sides of the process. We combine strategic legal defense with real accounting precision to protect your money, reputation, and peace of mind.

We act fast, we act smart, and we act in your best interest—because when the CRA comes knocking, you need more than an accountant. You need an ally.

Call Mackisen CPA Auditors Montreal today for your 2025 Reassessment Defense Consultation. The first meeting is free, and your protection begins immediately.