CRA Payroll Remittance Audit 2025 — Defend Your Business, Avoid Personal Liability, and Eliminate CRA Penalties

CRA’s Payroll Remittance Audit Division has become one of the most aggressive enforcement branches in Canada. With AI-driven systems matching T4 slips, PD7A filings, and bank transactions, CRA is identifying even minor inconsistencies in payroll deductions. Many businesses are being hit with reassessments for late remittances, inaccurate CPP/EI calculations, or missing source deductions, and directors are being personally charged for unpaid balances. At Mackisen CPA Auditors Montreal, we defend employers, directors, and payroll managers from CRA’s aggressive collection and audit tactics. Our CPA auditors and tax lawyers ensure compliance, correct past filings, and eliminate penalties under the Taxpayer Relief Program. We don’t let administrative errors destroy your reputation — we rebuild your defense and your financial integrity.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 153(1): Requires employers to withhold income tax, CPP, and EI on employee wages. Section 227.1(1): Holds directors personally liable for unremitted source deductions, unless due diligence can be proven. Section 162(1): Imposes late-filing penalties that Mackisen cancels through proactive disclosure and relief applications. Section 220(3.1): Permits CRA to cancel or reduce penalties and interest through the Taxpayer Relief Program. Section 165(1): Provides the right to dispute CRA reassessments through a Notice of Objection.
Employment Insurance Act and Canada Pension Plan Act These acts govern the calculation and remittance of employer and employee contributions. Mackisen ensures your payroll systems meet federal and provincial requirements while defending against CRA’s assumptions.
Tax Administration Act (Quebec) Revenu Québec applies parallel rules for QPP, QPIP, and Health Services Fund contributions. Mackisen manages both jurisdictions to ensure a unified and compliant response.

Key Court Decisions

Bédard v. The Queen (2022): CRA must prove negligence before enforcing director liability. Thibault v. The Queen (2022): Administrative or accounting errors do not justify gross negligence penalties. Buckingham v. The Queen (2011 FCA): Directors who maintain oversight and delegate responsibilities appropriately are protected from personal liability. Guindon v. Canada (2015): Honest reliance on professionals eliminates penalties for gross negligence. These precedents confirm that employers and directors can avoid penalties with documented due diligence and proper defense.

Why CRA Targets Payroll Remittances

CRA’s 2025 audit system automatically flags late or missing payroll filings, mismatched T4s, and unremitted deductions. Common triggers include payroll payments made after due dates, incorrect CPP/EI calculations, unreported bonuses, and misclassified contractors. CRA assumes negligence — Mackisen proves administrative good faith and compliance.

Mackisen’s Payroll Remittance Defense Strategy

1. Audit File Review: Analyze CRA’s reassessment and confirm whether calculations are accurate or overstated. 2. Documentation Reconciliation: Rebuild payroll records, T4s, PD7As, and remittance schedules to ensure consistency. 3. Due Diligence Proof: Demonstrate director oversight and procedural compliance to avoid personal liability. 4. Formal Objection Filing: Submit a Notice of Objection to suspend CRA collection and contest the audit results. 5. Penalty & Interest Relief: File under Section 220(3.1) to remove or reduce penalties caused by late or incorrect remittances. Mackisen’s process ensures CRA’s findings are corrected, and your company’s compliance is fully restored.

Real Client Experience

A Montreal transportation company was assessed $214,000 for “missing source deductions.” Mackisen reconstructed payroll records and CRA withdrew the entire reassessment. A Quebec medical clinic faced $96,000 in penalties for “incorrect remittances.” Mackisen proved accounting error and CRA cancelled all fines.

Common Questions

Can CRA hold directors personally responsible for payroll debts? Yes, but Mackisen provides evidence of due diligence to prevent liability. Can CRA audit payroll retroactively? Yes, generally within four years — Mackisen enforces these limits. Can CRA charge penalties for late remittances even if paid? Yes, but Mackisen secures relief under the Taxpayer Relief Program. Can I appeal a payroll reassessment? Absolutely — Mackisen files a Notice of Objection and manages full appeal representation.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s most experienced defenders in payroll remittance audits. Our integrated team of CPAs and tax lawyers combines accounting precision with legal strength to eliminate CRA penalties and protect corporate and personal assets. We act quickly, prove compliance, and defend effectively — because good employers deserve good representation. When CRA audits your payroll, Mackisen audits their findings. Call Mackisen CPA Auditors Montreal today for your 2025 Payroll Remittance Audit Defense Consultation. The first meeting is free, and your protection starts immediately.