CRA Payroll Tax Debt Relief 2025 — Stop CRA Collections, Protect Your Business, and Erase Payroll Penalties with Mackisen

CRA’s Payroll Enforcement Division is cracking down on employers with outstanding source deductions, missed remittances, or payroll reporting errors. Even small administrative mistakes can result in large reassessments, interest, and personal liability for directors. CRA’s automated systems are now cross-referencing PD7A slips, T4 filings, and bank records to detect discrepancies instantly. Many businesses are being blindsided with sudden bank freezes or wage garnishments before they even have a chance to explain. At Mackisen CPA Auditors Montreal, we stop CRA payroll collections fast. Our CPA auditors and tax lawyers negotiate directly with CRA to remove penalties, reduce interest, and create sustainable repayment plans. We don’t let payroll errors become financial disasters — we protect your business, your employees, and your future.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 153(1): Requires employers to withhold and remit income tax, CPP, and EI contributions. Section 227.1(1): Makes corporate directors personally liable for unremitted source deductions unless due diligence is proven. Section 162(1): Imposes late payment penalties that can be cancelled under Section 220(3.1) of the Taxpayer Relief Program. Section 225.1(1): Suspends CRA’s collection powers while a valid objection is under review. Section 165(1): Gives taxpayers the right to formally dispute CRA reassessments.
Employment Insurance Act and Canada Pension Plan Act These acts govern employer remittance obligations and benefit calculations. Mackisen ensures your compliance and negotiates with CRA to minimize exposure.
Tax Administration Act (Quebec) Revenu Québec enforces payroll-related obligations for QPP, QPIP, and the Health Services Fund. Mackisen manages both levels to ensure full coordination and relief.

Key Court Decisions

Bédard v. The Queen (2022): CRA must prove employer negligence before enforcing director liability. Thibault v. The Queen (2022): Accounting errors do not qualify as gross negligence. Buckingham v. The Queen (2011 FCA): Directors who exercise oversight and act promptly can avoid personal liability. Guindon v. Canada (2015): Honest reliance on professional advice protects against severe penalties. These rulings confirm that documented good faith and timely corrective action protect employers from payroll-related penalties.

Why CRA Targets Payroll Debts

CRA’s 2025 compliance strategy focuses on missed payroll source deductions, inaccurate PD7A filings, and late T4 submissions. Common triggers include financial hardship, accountant delays, or administrative mistakes. CRA assumes negligence — Mackisen proves compliance and due diligence.

Mackisen’s Payroll Debt Relief Strategy

1. Immediate Intervention: Contact CRA Collections to suspend garnishments or bank freezes. 2. Liability Assessment: Verify the accuracy of CRA’s reassessment and confirm responsibility. 3. Negotiation & Settlement: Secure payment arrangements or full penalty waivers through direct CRA negotiation. 4. Formal Objection Filing: Dispute inaccurate assessments under Section 165(1). 5. Taxpayer Relief Application: File under Section 220(3.1) to cancel interest and penalties due to hardship or administrative error. Mackisen ensures your payroll issues are resolved quickly, completely, and legally.

Real Client Experience

A Montreal construction firm faced $212,000 in payroll tax arrears. Mackisen negotiated with CRA, proved compliance, and reduced the balance by 80 percent. A Quebec dental clinic had bank accounts frozen for missed payroll remittances. Mackisen filed a relief request and CRA released funds within 48 hours.

Common Questions

Can CRA hold me personally liable for payroll debt? Only if you failed to act with due diligence — Mackisen documents your compliance to prevent liability. Can CRA cancel payroll penalties? Yes, through the Taxpayer Relief Program. Can CRA collect payroll debt while I appeal? No, collections stop when Mackisen files a Notice of Objection. Can CRA forgive payroll interest? Absolutely, if financial hardship or administrative error is demonstrated.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leaders in payroll tax defense and debt relief. Our integrated team of accountants and tax lawyers acts fast to stop CRA collections, remove penalties, and restore financial stability. We act decisively, negotiate strategically, and defend effectively — because good employers deserve fair treatment. When CRA pressures your payroll, Mackisen protects your business. Call Mackisen CPA Auditors Montreal today for your 2025 Payroll Tax Debt Relief Consultation. The first meeting is free, and your protection starts immediately.