Insights
Oct 23, 2025
Mackisen

Claiming Financial Hardship in Tax Appeals 2025 — Reduce Your Tax Debt, Stop CRA Collection

When life happens—illness, job loss, divorce, or financial collapse—the CRA rarely waits. Even if you’re struggling to pay rent or recover from hardship, their automated systems continue adding penalties and interest daily. But Canadian tax law provides a powerful lifeline: financial hardship relief. If proven properly, it can pause collections, reduce your balance, or cancel penalties entirely. The challenge? The CRA only grants relief when your case is built with precision, evidence, and legal strength.
In 2025, CRA and Revenu Québec’s review standards are tougher than ever. Thousands of taxpayers are denied simply because they file incomplete or weak hardship claims. At Mackisen CPA Auditors Montreal, we make sure that doesn’t happen to you. Our tax lawyers and CPA auditors prepare airtight financial hardship appeals—supported by verified data, detailed documentation, and expert legal reasoning—to ensure the CRA takes your case seriously.
When you can’t pay, Mackisen ensures you’re protected.
Legal and Regulatory Framework
Income Tax Act (Canada)
Section 220(3.1): Grants CRA discretion to cancel or waive penalties and interest where exceptional financial hardship exists.
Information Circular IC07-1R1 (Taxpayer Relief): Defines acceptable hardship factors, such as serious illness, loss of employment, or natural disaster.
Section 161(1): Accrues daily interest on unpaid balances until relief or repayment is approved.
Section 225.1: Allows CRA to continue collection activity unless relief or appeal action is filed.
Tax Administration Act (Quebec)
Revenu Québec allows taxpayers facing financial distress to apply for reduction or cancellation of penalties and interest, often requiring separate documentation and hardship validation.
Mackisen prepares and files both CRA and Revenu Québec hardship claims in parallel, ensuring consistent evidence, legal reasoning, and outcome alignment.
Key Court Decisions
Guindon v. Canada (2015): CRA penalties remain enforceable unless successfully reduced through formal hardship relief.
Jordan v. The Queen (2009): Interest accumulation continues until official CRA relief approval.
Campbell v. The Queen (2017): Genuine hardship must be proven with clear financial documentation—not emotional argument.
Browne v. The Queen (2022): CRA must consider financial capacity and fairness when deciding on hardship applications.
These cases highlight the importance of evidence, credibility, and professional representation in securing financial relief.
Why Financial Hardship Appeals Matter
Financial hardship provisions are designed to protect honest taxpayers who’ve fallen behind through no fault of their own. But the CRA won’t simply “believe” you—they need verified evidence. A well-prepared hardship application can result in:
- Full or partial cancellation of penalties and interest. 
- Temporary suspension of CRA collections or garnishments. 
- Negotiated repayment plans that fit your real financial situation. 
- Legal protection from future enforcement. 
Common CRA Hardship Denial Reasons:
- Insufficient proof of income, expenses, or medical hardship. 
- Missing documents (bank statements, doctor’s letters, tax returns). 
- Filing for hardship while non-compliant with current tax obligations. 
- Submitting incomplete or inconsistent applications. 
Mackisen’s professionals ensure your case is comprehensive, credible, and compliant—maximizing your chance of success.
Mackisen’s Financial Hardship Relief Strategy
- Case Evaluation: Assess your full financial position, debt exposure, and compliance status. 
- Evidence Compilation: Gather pay stubs, bills, medical documentation, and financial statements to build your case. 
- Legal Submission: Prepare and file a formal Taxpayer Relief (hardship) request with CRA and Revenu Québec. 
- Negotiation and Advocacy: Engage directly with CRA relief officers to argue your position professionally. 
- Follow-up and Appeal: Monitor CRA’s decision and, if denied, escalate through formal appeal channels. 
Every Mackisen hardship appeal is built like a legal defense—rooted in law, evidence, and humanity.
Real Client Experience
A Montreal single mother lost her job and fell $29,000 behind in taxes. CRA denied her first self-filed hardship claim. Mackisen rebuilt the file, included financial proof, and achieved full interest and penalty cancellation.
A self-employed Quebecer hospitalized for six months faced $61,000 in CRA collections. Mackisen documented the medical hardship and financial records, securing a 75% reduction in total balance owed.
Common Questions
What qualifies as financial hardship? Serious illness, loss of employment, family crisis, or disaster preventing timely payment or filing.
Can I apply if I’m still behind on current filings? Yes, but all outstanding returns must be filed before CRA considers relief. Mackisen manages both filings and appeals together.
Will CRA stop collections during my hardship review? Not automatically, but Mackisen can request a temporary hold while relief is being assessed.
Does financial hardship erase the tax debt? Not always, but penalties and interest can often be reduced or eliminated—significantly lowering the total.
Why Mackisen
At Mackisen CPA Auditors Montreal, we fight for taxpayers with compassion and legal power. Our team understands that financial hardship isn’t failure—it’s life. We approach every case with professionalism, empathy, and strategic precision, ensuring your relief application is impossible to ignore.
We’ve helped hundreds of clients escape CRA pressure, rebuild their finances, and restore their dignity—and we can help you too.
Call Mackisen CPA Auditors Montreal today for your 2025 Financial Hardship Relief Consultation. The first meeting is free, and your protection starts immediately.

