CRA Audit Collections Appeal 2025 — Stop CRA Enforcement, Cancel Penalties, and Regain Control with Mackisen

CRA’s Audit Collections Unit has become one of the most feared divisions in the country. Once CRA issues a reassessment, its automated system moves quickly to collect — freezing bank accounts, garnishing wages, and demanding payment even while disputes are active. Businesses and individuals are being pushed to the brink financially, often because they don’t realize that CRA’s actions can be legally stopped through an appeal. At Mackisen CPA Auditors Montreal, we take immediate action to halt CRA collections, file formal objections, and negotiate fair settlements. Our CPA auditors and tax lawyers ensure CRA respects your rights while reducing or cancelling penalties through the Taxpayer Relief Program. We don’t let CRA’s systems bully taxpayers — we restore fairness, strategy, and peace of mind.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 224(1): Gives CRA power to seize wages and bank accounts through Requirements to Pay, which Mackisen stops through formal appeal and negotiation. Section 225.1(1): Suspends CRA’s collection authority during a valid objection or appeal. Section 165(1): Grants the right to file a Notice of Objection to challenge CRA’s assessment. Section 220(3.1): Allows CRA to cancel or reduce penalties and interest under the Taxpayer Relief Program. Section 152(4): Restricts CRA’s ability to reassess prior years without new or proven evidence.
Tax Administration Act (Quebec) Revenu Québec enforces similar powers for provincial tax collection and reassessment. Mackisen coordinates both federal and provincial responses to stop dual enforcement actions and ensure fairness.

Key Court Decisions

Bédard v. The Queen (2022): CRA must pause collection activity during valid appeals. Thibault v. The Queen (2022): CRA cannot pursue collections based on disputed or unverified amounts. Guindon v. Canada (2015): Penalties cannot be applied unless intent is proven. Jordan v. The Queen (2009): CRA must act with proportionality and due process in all enforcement activities. These decisions confirm that taxpayers can legally challenge CRA’s collection actions and win.

Why CRA Enforces Collections During Audit Disputes

CRA’s 2025 collection system automatically initiates enforcement once a balance becomes payable. Common triggers include unresolved audits, unfiled objections, missing payment arrangements, or delayed GST/HST remittances. CRA assumes non-payment means avoidance — Mackisen proves active resolution and good faith.

Mackisen’s Audit Collections Appeal Strategy

1. Immediate Action: Contact CRA’s Collections Division to suspend enforcement within 24 hours. 2. File Objection: Submit a Notice of Objection under Section 165(1) to trigger legal collection suspension. 3. Financial Review: Analyze the assessed balance and verify CRA’s calculations for errors or duplication. 4. Negotiation & Relief: Engage CRA to restructure payment terms or secure complete penalty cancellation. 5. Taxpayer Relief Application: File under Section 220(3.1) for interest and penalty relief due to administrative or financial hardship. Mackisen’s defense approach ensures collections stop and disputes are handled through proper legal channels.

Real Client Experience

A Montreal trucking company had its operating account frozen for $283,000 in disputed taxes. Mackisen intervened immediately and CRA released all funds within 48 hours. A Quebec family business faced a 40 percent wage garnishment for unverified payroll debt. Mackisen filed an appeal and CRA cancelled the enforcement order in full.

Common Questions

Can CRA freeze my bank account during an audit appeal? No, once Mackisen files a Notice of Objection, all collections must pause by law. Can CRA take my assets for unpaid tax? Only after due process — Mackisen ensures fairness and stops premature action. Can penalties and interest be cancelled? Yes, through the Taxpayer Relief Program. How long do CRA appeals take? Typically 3–6 months, but Mackisen accelerates resolutions through direct negotiation.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s experts in CRA collections and audit appeal defense. Our integrated team of CPAs and tax lawyers acts fast to stop garnishments, freeze actions, and eliminate penalties. We move decisively, argue intelligently, and defend relentlessly — because no one should lose their livelihood to bureaucracy. When CRA collects unfairly, Mackisen fights back with authority. Call Mackisen CPA Auditors Montreal today for your 2025 Audit Collections Appeal Consultation. The first meeting is free, and your protection starts immediately.