CRA Penalty Relief 2025 — Cancel Interest, Remove Fines, and Restore Financial Fairness with Mackisen CPA

In 2025, CRA’s Penalty Relief Program is the last line of defense for thousands of Canadians hit with unjust tax penalties. Automated assessments now issue late filing, gross negligence, and instalment penalties instantly — even when the fault lies with CRA system delays, accountant errors, or genuine hardship. Many taxpayers are paying thousands they don’t owe simply because they never applied for relief. At Mackisen CPA Auditors Montreal, we specialize in securing full penalty and interest cancellation under the Taxpayer Relief Provisions. Our CPA auditors and tax lawyers prepare legally sound applications that document cause, demonstrate fairness, and compel CRA to act. We don’t request relief — we make the case for it. When CRA penalizes life’s disruptions, Mackisen restores justice.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 220(3.1): Gives CRA authority to cancel or reduce penalties and interest when circumstances justify.

• Section 162(1): Imposes late filing penalties (5% + 1% per month).

• Section 163(2): Imposes 50% gross negligence penalties, which Mackisen can have removed through relief.

• CRA IC07-1R1 (Taxpayer Relief Guidelines): Lists qualifying grounds such as financial hardship, CRA error, or extraordinary events.
  Tax Administration Act (Quebec)
  Revenu Québec mirrors the federal penalty relief process. Mackisen manages both applications simultaneously to ensure full elimination of penalties at every level.

Key Court Decisions

Guindon v. Canada (2015): Honest taxpayers acting under professional advice should not face gross negligence penalties.
Bédard v. The Queen (2022): CRA must apply fairness and consider individual hardship when evaluating relief.
Thibault v. The Queen (2022): System errors and professional reliance justify full penalty cancellation.
Jordan v. The Queen (2009): CRA’s discretion under Section 220(3.1) must be exercised reasonably and transparently.
These rulings confirm that CRA penalties can be fully cancelled with proper representation and supporting evidence.

Why CRA Imposes Unfair Penalties

CRA’s automated systems issue penalties automatically, without considering context or human factors. Common 2025 penalty triggers include:

• Filing or payment delays caused by illness or disaster.

• CRA system or EFILE transmission failures.

• Incorrect tax slips or accountant misfilings.

• Financial hardship preventing timely payment.

• CRA reassessment delays or communication errors.
  CRA assumes negligence — Mackisen proves reasonableness.

Mackisen’s Penalty Relief Strategy

1. Penalty Review: Identify all penalties and interest applied across CRA accounts.

2. Cause Documentation: Gather proof of illness, hardship, CRA delay, or third-party error.

3. Formal Relief Application: File under Section 220(3.1) with legal, factual, and financial justification.

4. Negotiation & Follow-Up: Engage CRA’s relief officers until written confirmation of penalty removal is issued.

5. Provincial Coordination: File corresponding relief requests with Revenu Québec for complete clearance.
   Our process ensures every penalty is reviewed under law, not automation.

Real Client Experience

A Montreal entrepreneur was charged $186,000 in late filing penalties due to accountant delays. Mackisen filed for relief and CRA cancelled all penalties and interest.
A Quebec senior owed $42,000 in interest after CRA’s EFILE system crashed. Mackisen proved administrative fault and secured full refund.

Common Questions

Can CRA cancel both penalties and interest? Yes — Mackisen routinely achieves full cancellation under Section 220(3.1).
How far back can I apply for relief? Ten years from the end of the tax year in question. Mackisen ensures no deadline is missed.
Do I qualify for relief if my accountant made a mistake? Yes — professional error is a valid ground under CRA guidelines.
Can I appeal if CRA denies my relief request? Yes — Mackisen can escalate to Federal Court if CRA acts unfairly.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leaders in CRA penalty and interest relief. Our firm combines legal reasoning, accounting expertise, and persuasive advocacy to ensure fairness is restored. We act fast, document meticulously, and negotiate relentlessly — because mistakes shouldn’t cost you your future. When CRA fines you unfairly, Mackisen fines their process.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Penalty Relief Consultation. The first meeting is free, and your recovery starts immediately.