CRA Audit Support, Reviews & Objections

If you have received a CRA letter, do not call CRA back yourself

Most Canadian taxpayers contacted by the Canada Revenue Agency for a review, audit, or reassessment make the situation worse by responding too quickly and too informally. CRA review letters and audit notices have specific legal effects, strict deadlines, and require careful documentation. What you say in an early phone call to CRA can become the basis for the reassessment. What you fail to provide can be deemed admitted. Once an assessment is issued, the only formal way to dispute it is the Notice of Objection process — and that has a hard 90-day deadline.

BOMCAS Canada handles CRA correspondence on behalf of clients every week. With your signed authorization on file (RC59 for businesses or AUT-01 for individuals), we communicate with CRA directly, control the pace of the file, gather and present documentation professionally, and protect your rights at every stage. In many cases we are able to resolve files at the pre-assessment review stage before an assessment is even issued.

Types of CRA contact we handle

• Pre-assessment reviews (CRA requesting documentation before issuing the Notice of Assessment)
• Post-assessment reviews and processing reviews (CRA requesting documentation after assessment)
• Desk audits (CRA requesting more comprehensive records by mail)
• Field audits (CRA auditor reviewing books at the place of business or virtually)
• GST/HST audits targeting tax collected, ITCs claimed, or registration timing
• Payroll audits targeting source deductions, T4s, or worker classification (employee vs contractor)
• Net worth audits where CRA reconstructs income from lifestyle and asset changes
• Notices of Reassessment with proposed additional tax
• Demands to file from CRA Non-Filer programs
• Voluntary Disclosure Program (VDP) submissions for unreported income or unfiled returns coming forward voluntarily
• Taxpayer Relief applications for penalty and interest cancellation in extraordinary circumstances
• Notices of Objection (T400A) to formally dispute a Notice of (Re)Assessment
• Tax Court of Canada appeals in coordination with tax counsel
• CRA collections negotiations for taxpayers with assessed debt who cannot pay in full

The audit defence process

1. Authorization. You sign RC59 or AUT-01 authorizing BOMCAS to communicate with CRA on your behalf. From that point forward, all CRA contact routes through us.
2. Internal review. Before responding to CRA, we review the year(s) under review, identify weak spots, gather supporting documentation, and identify any issues CRA has not yet flagged but should be expected to flag.
3. Response strategy. We decide what to provide, how to present it, and what cover narrative to include. We provide what is requested — nothing more, nothing less. We do not volunteer information.
4. Submission. We submit through CRA’s online portal or by registered mail, always documented and tracked.
5. Follow-up. We track CRA response timing, respond to any follow-up requests, and push for resolution.
6. Outcome management. If CRA agrees, we close the file. If CRA proposes adjustments we dispute, we move to Notice of Objection within the 90-day deadline.
7. Appeals if needed. If Appeals Division does not resolve the dispute, we coordinate with tax counsel for a Tax Court of Canada appeal.

Voluntary Disclosure Program — the way back from non-compliance

If you have unreported income, unfiled returns, or undisclosed foreign assets, the Voluntary Disclosure Program (VDP) can provide significant penalty relief and reduce interest, provided you come forward before CRA contacts you. VDP applications must be voluntary (no prior CRA contact), complete, involve a penalty that would otherwise apply, and involve information at least one year overdue. The 2018 VDP reforms split the program into a General Program (full relief) and a Limited Program (reduced relief for major non-compliance), and tightened the bar significantly. We assess VDP eligibility carefully and prepare submissions that meet the program’s requirements.

Frequently asked questions

What Canadian businesses commonly miss about this service

Across the hundreds of Canadian businesses we work with, the same handful of issues come up repeatedly. Many small business owners delay engaging professional accounting until a crisis: a CRA review letter, an unfiled GST/HST return demand, a denied bank loan because financial statements aren't ready, or a Notice of Reassessment that arrived weeks ago. By the time we are first contacted, the cost to fix the problem is often several times what proper ongoing accounting would have cost from the start. Proactive engagement is dramatically cheaper than reactive cleanup.

The Canadian tax landscape also changes constantly. Recent changes that affect most Canadian taxpayers include the 2023 anti-flipping rule (residential real estate sold within 365 days is automatically business income, not capital gain); the Underused Housing Tax (UHT-2900 annual filing requirement for many corporations, partnerships, and trusts holding residential property even when no tax is owing — with $5,000 to $10,000 per-property failure-to-file penalties); the Quebec QST joint registration changes since 2021; the post-2018 Tax on Split Income (TOSI) rules that effectively eliminated casual income splitting through family dividends; the post-2021 $200,000 stock option vesting limit on the 50% deduction for options granted by non-CCPCs; the CSRS 4200 Compilation Engagement standard replacing the older Notice to Reader engagement; and ongoing CRA increased scrutiny on pre-construction assignments, short-term rental businesses, and cash businesses.

How BOMCAS Canada delivers this service

Every engagement begins with a written, fixed-fee engagement letter signed before any work is performed. The engagement letter describes exactly what is in scope, what deliverables you will receive, when those deliverables are due, what your monthly or project fee is, and what (if anything) is outside scope. This eliminates the hourly-billing surprise that most accounting clients fear. The only time we use hourly billing is for genuinely unpredictable items such as CRA audit response or complex one-off projects — and even then we agree to a maximum cap before starting.

Once the engagement letter is signed, you e-sign the CRA authorization (RC59 for businesses or AUT-01 for individuals), and we onboard you to the encrypted client portal with multi-factor authentication. All document exchange flows through the portal — no emailing of sensitive financial documents. Meetings happen by video conference or phone at times that work for you, including outside normal business hours when needed.

Our Canadian tax compliance philosophy

BOMCAS Canada is structured around four operating principles:

1. Tell the truth. If a tax position is aggressive, we say so. If a deduction will not survive a CRA review, we say so. If the engagement is going to cost more than originally quoted because the scope changed, we say so before doing the work.
2. Bill what we said we would bill. No surprise invoices. No scope-creep billing. If something legitimately changes scope, we discuss it and re-quote before doing the additional work.
3. Answer the phone. One-business-day response standard on client communications during normal business hours. No voicemail backlogs.
4. Specialize. Canadian tax and accounting is too complex to be a generalist. We do not do US-only tax, UK tax, or any other foreign jurisdiction in isolation. We are Canadian. Our cross-border work is always anchored by deep Canadian compliance.

What ongoing engagement with BOMCAS Canada looks like

For most clients, the ongoing relationship is structured around predictable monthly deliverables. For an incorporated small business client, that typically includes: monthly cloud bookkeeping with full bank and credit card reconciliation; quarterly or annual GST/HST returns prepared and filed; monthly payroll for owner-managers and any employees, with CRA source deduction remittances; year-end Compilation Engagement (CSRS 4200) financial statements; T2 corporate income tax return; owner-manager T1 personal tax return (and spouse where applicable); annual salary-vs-dividend optimization with written recommendation; unlimited email and phone support during business hours; one quarterly check-in call to review numbers and discuss the business; and CRA correspondence handling for routine review letters.

For a personal tax client, the ongoing engagement includes: annual T1 preparation; any required Quebec TP-1 (for Quebec residents); CRA pre-assessment and post-assessment review response when CRA requests additional documentation; Notice of Assessment reconciliation; and proactive tax planning conversations during the year about RRSP, TFSA, and FHSA contributions, major life events (marriage, kids, retirement, real estate), and any planned business or investment changes.

Frequently asked questions about engaging BOMCAS Canada

Why Canadian businesses choose specialized accounting over generalist accounting

The Canadian tax and accounting landscape has become significantly more complex over the past decade. The 2018 TOSI rules, the 2021 changes to stock option taxation, the 2022 mandatory reporting changes for trusts, the 2023 anti-flipping rule, the Underused Housing Tax, the changes to the small business deduction phase-out for passive investment income, the new CSRS 4200 Compilation Engagement standard, the continued expansion of digital sales tax rules, and the ongoing post-COVID CRA focus on cash businesses and unreported income have all required accountants to specialize more deeply. A generalist firm trying to cover personal tax, corporate tax, US tax, real estate, trusts, cross-border, and every industry vertical inevitably falls behind on the depth of expertise that any one client needs.

BOMCAS Canada is structured deliberately to maintain depth: we are Canadian-only by design; we work in industries where we have genuine specialized experience; we maintain ongoing professional education in Canadian tax law; we use Canadian-experienced staff at every level; and we coordinate with specialized partners (US-licensed cross-border, legal counsel for corporate restructuring, audit-engagement licensed practitioners) where required rather than trying to handle everything in-house.

Talk to a Canadian accountant

Call 780-667-5250 or submit the contact form. We respond within one business day and provide a fixed written quote before any work begins.

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