CRA Audit Settlement 2025 — Resolve Disputes, Reduce Tax Debt, and Close Your Case with Mackisen CPA

In 2025, CRA’s Audit Settlement Division is expanding its use of negotiated resolutions to close complex tax disputes faster. With CRA’s AI audit systems issuing thousands of reassessments based on estimated data, many taxpayers — from small businesses to high-net-worth individuals — are left facing inflated tax bills and penalties that don’t reflect reality. CRA auditors often overstate income, deny deductions, or misclassify transactions, then push for quick payment. At Mackisen CPA Auditors Montreal, we negotiate strategic CRA Audit Settlements that reduce taxes owed, remove penalties, and resolve disputes without litigation. Our CPA auditors and tax lawyers present evidence-based proposals that convince CRA to compromise. We don’t let CRA’s assumptions drain your finances — we close cases with fairness, precision, and strength.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 165(1): Grants the right to file a Notice of Objection — Mackisen uses this to pause collections while negotiating settlements.

• Section 169: Allows escalation to the Tax Court of Canada when CRA refuses fair resolution.

• Section 220(3.1): Enables CRA to cancel or reduce penalties and interest through the Taxpayer Relief Program as part of settlement terms.

• Section 225.1(1): Suspends CRA collections during formal dispute resolution.
  Tax Administration Act (Quebec)
  Revenu Québec allows equivalent negotiated settlements to close reassessments or dual-agency audits. Mackisen manages both agencies to ensure global resolution.

Key Court Decisions

Bédard v. The Queen (2022): CRA must act fairly and consider taxpayer-provided documentation during settlements.
Thibault v. The Queen (2022): Settlement discussions based on factual corrections are valid and binding once accepted.
Guindon v. Canada (2015): Good faith and cooperation negate CRA’s right to impose gross negligence penalties.
Jordan v. The Queen (2009): CRA must prioritize fair resolution over prolonged reassessment disputes.
These precedents confirm that CRA settlements can reduce debt and penalties dramatically when handled professionally.

Why CRA Offers Settlements

CRA’s 2025 settlement push aims to recover revenue efficiently and avoid Tax Court overload. Common triggers include:

• Conflicting interpretations of business expenses or income.

• Missing documentation now reconstructed post-audit.

• Partial errors in CRA’s assessment methodology.

• CRA resource limits preventing prolonged litigation.

• Genuine financial hardship or insolvency risk.
  CRA seeks recovery — Mackisen secures fairness.

Mackisen’s Audit Settlement Strategy

1. Audit Review: Evaluate CRA’s reassessment and identify negotiable or erroneous components.

2. Evidence Preparation: Compile corrected records, valuations, and professional reports to strengthen leverage.

3. Settlement Proposal: Submit a documented compromise supported by law, fairness, and precedent.

4. Negotiation & Mediation: Engage CRA’s Appeals and Settlement Officers directly to achieve resolution.

5. Penalty & Interest Relief: Integrate a Taxpayer Relief Request under Section 220(3.1) as part of settlement terms.
   Our process ensures maximum reduction of tax debt with minimum confrontation.

Real Client Experience

A Montreal importer faced a $472,000 CRA reassessment for “unreported sales.” Mackisen negotiated based on corrected supplier data and CRA reduced the debt by 82%.
A Quebec family business was charged $136,000 in payroll penalties. Mackisen demonstrated administrative error and CRA cancelled all fines.

Common Questions

Can CRA negotiate settlements? Yes — Mackisen negotiates with CRA Appeals and Settlement Divisions on your behalf.
Will a settlement stop CRA collections? Yes — filing an objection and entering negotiation pauses enforcement.
Do I have to admit wrongdoing to settle? No — Mackisen ensures settlements reflect clarification, not fault.
Can CRA remove interest and penalties in settlement? Absolutely — Mackisen secures full relief under the Taxpayer Relief Program.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leaders in negotiating successful CRA audit settlements. Our dual team of CPAs and tax lawyers brings the right balance of accounting precision and legal strategy to resolve even the toughest cases. We act quickly, negotiate intelligently, and deliver results — because every dispute deserves closure, not chaos. When CRA audits your finances, Mackisen audits their fairness.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Audit Settlement Consultation. The first meeting is free, and your protection starts immediately.