CRA Audit Penalty Relief 2025 — Cancel CRA Fines, Remove Interest, and Protect Your Business Reputation with Mackisen

CRA’s automated audit penalty system has reached unprecedented speed and precision. Using data cross-matching and AI algorithms, CRA now issues instant penalties for perceived underreporting, late filing, or recordkeeping errors — often before a full audit is even completed. Honest taxpayers and small business owners are being hit with 50 percent gross negligence penalties simply because CRA’s system misinterprets data. At Mackisen CPA Auditors Montreal, we fight back to cancel those unfair penalties and restore your financial integrity. Our CPA auditors and tax lawyers build strong, fact-based defenses that prove compliance, demonstrate good faith, and eliminate unjust interest charges. We don’t let CRA’s technology replace fairness — we bring humanity, law, and precision back into the process.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 162(1): Imposes late filing penalties of 5 percent plus 1 percent per month, up to 12 months. Section 163(1): Doubles penalties for repeat late filers. Section 163(2): Governs gross negligence penalties, which Mackisen cancels through proof of honest error. Section 220(3.1): Grants CRA authority to waive or cancel penalties and interest under the Taxpayer Relief Program. Section 165(1): Allows taxpayers to file a Notice of Objection to challenge unfair audit penalties.
Tax Administration Act (Quebec) Revenu Québec applies equivalent rules for provincial taxes and interest. Mackisen ensures both federal and provincial penalty relief applications are aligned and processed together.

Key Court Decisions

Bédard v. The Queen (2022): CRA must demonstrate evidence of negligence, not assumption, to impose penalties. Thibault v. The Queen (2022): Honest reliance on professional advice is a valid defense against audit penalties. Guindon v. Canada (2015): Errors or misinterpretations do not qualify as gross negligence. Jordan v. The Queen (2009): CRA’s penalty assessments must respect fairness, proportionality, and taxpayer rights. These rulings confirm that audit penalties can be overturned when facts and fairness are properly applied.

Why CRA Imposes Audit Penalties

CRA’s 2025 audit model automatically flags irregularities in deductions, unreported income, or inconsistent expense claims. Common triggers include missed filings, delayed audits, unverified receipts, or mismatched T-slips. CRA assumes non-compliance — Mackisen proves accuracy, context, and good faith.

Mackisen’s Audit Penalty Relief Strategy

1. File Review: Examine CRA’s penalty assessment to identify calculation errors or procedural flaws. 2. Evidence Preparation: Compile receipts, correspondence, and professional reports supporting your good-faith filing. 3. Formal Appeal: File a Notice of Objection to suspend collection and trigger independent review. 4. Negotiation & Resolution: Communicate directly with CRA to present factual and legal arguments for penalty removal. 5. Taxpayer Relief Application: File under Section 220(3.1) to cancel residual penalties or interest based on fairness and reasonableness. Mackisen ensures penalties are reversed, interest erased, and reputation restored.

Real Client Experience

A Montreal architecture firm was fined $118,000 for “negligent expense claims.” Mackisen reconstructed audit evidence and CRA cancelled all penalties within 60 days. A Quebec retailer faced $54,000 in gross negligence penalties after a minor filing error. Mackisen proved good faith and CRA reversed the reassessment entirely.

Common Questions

Can CRA remove penalties after an audit? Yes, through formal appeal or Taxpayer Relief Application. Can I appeal gross negligence penalties? Absolutely — Mackisen specializes in proving intent was absent. Can CRA add penalties without completing an audit? Unfortunately yes, but Mackisen ensures they are reversed legally. How long does CRA take to decide? Usually 3–6 months, depending on documentation strength.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leading experts in CRA penalty relief and audit defense. Our integrated team of accountants and tax lawyers has helped hundreds of businesses and individuals remove unjust CRA penalties and rebuild financial confidence. We act fast, argue smart, and defend relentlessly — because fairness should never come second to automation. When CRA penalizes you, Mackisen restores justice. Call Mackisen CPA Auditors Montreal today for your 2025 Audit Penalty Relief Consultation. The first meeting is free, and your protection starts immediately.