CPD Course for CPA - CRA Audit Defence and Objections: What CPAs Need to Know

Course Name: CRA Audit Defence and Objections: What CPAs Need to Know

CPD Hours: 2

Type: Online/Video

Price: ~~$120~~ $108

When the Canada Revenue Agency (CRA) initiates an audit or issues a aggressive reassessment, business clients turn to their CPAs as their primary line of defence. Navigating a CRA audit requires far more than basic tax compliance knowledgeâ€”it demands a deep mastery of administrative procedures, statutory authority, evidentiary standards, and strategic negotiation tactics.

CRA Audit Defence and Objections: What CPAs Need to Know is an intensive, practical Continuing Professional Development (CPD) masterclass designed specifically for Canadian CPAs, public practitioners, and tax advisors. This course equips practitioners with the knowledge and tools required to manage the entire tax dispute lifecycle: from initial CRA contact and AI risk-scoring analysis, through field audit negotiation, formal Notices of Objection, Tax Court litigation support, and interest/penalty relief applications.

Grounded in key provisions of the Income Tax Act (ITA) and Excise Tax Act (ETA) as well as foundational jurisprudence (Jarvis, Hickman Motors, Venne, DeCosta, Vavilov), this course transforms CPAs from reactive record-providers into authoritative client advocates.

Topic 1: CRA Audit Framework and Selection Criteria

1.1: CRA Audit Types, Scope, and Statutory Authority (ITA s. 231.1 / ETA s. 288)

1.2: Business Intelligence, AI Risk Scoring, and Trigger Factors

1.3: Initial Contact Protocol and Preliminary Risk Assessment

Topic 2: Navigating the Audit Lifecycle

2.1: Pre-Audit Preparation and CPA Representation Mandate (Form AUT-01)

2.2: Strategic Management of Requests for Information (RFIs)

2.3: Auditor Interaction Protocols and Scope Containment

Topic 3: High-Risk Audit Exposure Areas

3.1: Income Tax Audits and Expense Disallowance Triggers (ITA s. 18, 67, 230)

3.2: GST/HST Audit Risks and Wash Transaction Rules (CRA Policy P-209R / ETA s. 296(2.1))

3.3: Director Liability (ITA s. 227.1 / ETA s. 323) and Shareholder Benefits (ITA s. 15(1)/15(2))

Topic 4: Taxpayer Rights and Privilege Protection

4.1: Leveraging the Taxpayer Bill of Rights in Audits

4.2: Solicitor-Client Privilege vs. CPA Working Papers (Kovel Retainer Structures)

4.3: Handling Unreasonable Demands and RFI Deadline Extensions

Topic 5: Managing Audit Findings and Proposed Assessments

5.1: Analyzing Auditor Working Papers (T20 Reports) and Draft Findings

5.2: Formulating Effective Responses to 30-Day Proposal Letters

5.3: Pre-Assessment Negotiations and Settlement Strategies with Team Leaders

Topic 6: Notice of Objection Mechanics

6.1: Statutory Filing Deadlines and Form Requirements (T400A / GST159)

6.2: Drafting Comprehensive Legal and Factual Grounds and Rebutting CRA Assumptions

6.3: Navigating the CRA Appeals Division Procedure and ITA s. 169(1) Direct Appeal Window

Topic 7: Tax Court Appeals and Dispute Resolution

7.1: Tax Court Procedures: Informal vs. General Procedure Rules

7.2: Onus of Proof and Demolishing CRA Assumptions (Hickman Motors Standard)

7.3: Settlement Options, Pre-Trial Conferences, and Rule 147 Cost Offers

Topic 8: Penalty Mitigation and Taxpayer Relief

8.1: Defending Against Gross Negligence Penalties (ITA s. 163(2) / Venne and DeCosta Standards)

8.2: Subsection 220(3.1) Relief for Interest and Penalties (Form RC4288)

8.3: Voluntary Disclosures Program (VDP) Remedies and Limitations (IC00-1R6)