CRA Tax Appeal 2025 — Overturn CRA Decisions, Recover Your Money, and Protect Your Rights with Mackisen CPA

In 2025, CRA’s Tax Appeals Division is handling record-high reassessments as businesses and individuals fight back against unfair audits. CRA’s internal systems are now semi-automated, meaning many objections are reviewed by software before a human ever sees them. As a result, legitimate appeals are often denied without proper consideration. That’s where Mackisen CPA Auditors Montreal comes in. Our team of CPA auditors and tax lawyers builds strategic appeal cases that force CRA to look again — this time, correctly. We use law, facts, and documentation to reverse assessments, eliminate penalties, and restore your financial integrity. When CRA gets it wrong, Mackisen makes it right.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 169(1): Grants taxpayers the right to appeal to the Tax Court of Canada after CRA confirms or varies a reassessment.

• Section 165(1): Establishes the prior step of filing a Notice of Objection before appeal.

• Section 220(3.1): Allows for penalty and interest cancellation through the Taxpayer Relief Program.

• Section 152(4): Restricts CRA from reassessing beyond normal time limits without valid reason.
  Tax Court of Canada Act

• Defines formal and informal appeal procedures, allowing taxpayers to present evidence independently.
  Tax Administration Act (Quebec)
  Revenu Québec operates a similar appeal framework for provincial disputes. Mackisen coordinates federal and provincial appeals to ensure one unified legal defense.

Key Court Decisions

Bédard v. The Queen (2022): Taxpayers have the right to an impartial review at the appeal stage.
Thibault v. The Queen (2022): CRA’s burden of proof remains high — they must justify reassessments, not taxpayers.
Guindon v. Canada (2015): Penalties cannot apply when a taxpayer acts in good faith or under professional advice.
Venne v. The Queen (1984): CRA cannot rely on estimates or incomplete evidence to uphold a reassessment.
These decisions confirm that CRA’s reassessments can be overturned when challenged with proper documentation and legal expertise.

Why CRA Decisions Are Appealed

CRA appeal volumes have surged because automation has replaced judgment in reassessment processes. Common 2025 reasons for appeal include:

• CRA denying legitimate business expenses or input tax credits.

• Reclassification of income as business instead of capital gains.

• Denied Small Business Deduction eligibility.

• Unjust penalties under gross negligence provisions.

• Inconsistent application of tax treaties or residency rules.
  CRA assumes correctness — Mackisen proves error.

Mackisen’s Tax Appeal Strategy

1. Case Review: Evaluate CRA’s reassessment, objection outcome, and appeal deadlines.

2. Evidence Rebuild: Prepare all supporting documentation and expert reports to strengthen your case.

3. Legal Filing: Submit a detailed Notice of Appeal to the Tax Court of Canada within statutory timelines.

4. Representation & Negotiation: Engage CRA’s Appeals and Legal Services divisions to reach fair settlement or judgment.

5. Penalty & Interest Relief: Apply under Section 220(3.1) for relief after a successful appeal.
   Our approach combines litigation precision with financial expertise for maximum impact.

Real Client Experience

A Montreal manufacturer lost its Small Business Deduction after CRA reclassified management income. Mackisen appealed and won a full reversal at the Tax Court.
A Quebec investor was taxed twice on cross-border dividends. Mackisen proved treaty protection and CRA refunded all overpaid taxes and penalties.

Common Questions

How long do I have to appeal CRA’s decision? 90 days after CRA confirms the objection. Mackisen ensures appeals are filed on time.
Do I need to go to Tax Court? Not always — Mackisen often negotiates full resolution before formal hearings.
Can I represent myself? Technically yes, but CRA uses experienced lawyers — Mackisen levels the playing field.
Can penalties and interest be refunded after an appeal? Yes, once your appeal succeeds, Mackisen files for complete penalty cancellation.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s trusted authority in CRA appeals and tax litigation defense. Our combined expertise in accounting, law, and negotiation ensures your appeal is comprehensive, credible, and commanding. We act fast, present flawlessly, and win decisively — because justice in taxation isn’t optional, it’s essential. When CRA appeals cost you time and money, Mackisen restores both.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Tax Appeal Consultation. The first meeting is free, and your protection starts immediately.