Insights

Oct 25, 2025

Mackisen

CRA Tax Penalty Relief 2025 — Cancel CRA Fines, Reduce Interest, and Restore Your Financial Freedom

In 2025, CRA’s Penalty and Interest Enforcement System has become fully automated — instantly issuing fines for late filings, unremitted GST/HST, payroll errors, and even minor data mismatches. Thousands of Canadians are being hit with heavy penalties they don’t deserve, sometimes doubling their original tax balance. What CRA doesn’t tell you is that these penalties can be completely cancelled under the Taxpayer Relief Program — but only if your application is precise, documented, and professionally defended. At Mackisen CPA Auditors Montreal, we specialize in CRA Penalty Relief Applications that erase unfair penalties and interest. Our CPA auditors and tax lawyers use evidence, law, and compassion to secure full or partial forgiveness. We don’t let CRA’s automation dictate your destiny — we restore fairness and peace of mind.

Legal and Regulatory Framework

Income Tax Act (Canada)

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

  • Section 162(1): Imposes a 5% late filing penalty plus 1% per month, up to 12 months — Mackisen ensures full cancellation under valid grounds.

  • Section 163(1) & 163(2): Cover repeated or gross negligence penalties that Mackisen removes through proof of good faith.

  • Section 165(1): Allows taxpayers to file formal objections during penalty appeals.
    Excise Tax Act (Canada)

  • Provides parallel relief for GST/HST penalties on late or missing returns. Mackisen ensures federal and provincial relief are both granted.
    Tax Administration Act (Quebec)
    Revenu Québec mirrors CRA’s penalty framework. Mackisen manages both agencies to cancel all related interest and penalties in one unified process.

Key Court Decisions

Bédard v. The Queen (2022): CRA must exercise fairness and consider taxpayer intent before denying relief.
Thibault v. The Queen (2022): Financial hardship and professional reliance justify full penalty cancellation.
Guindon v. Canada (2015): Honest mistakes are not grounds for gross negligence.
Jordan v. The Queen (2009): CRA’s discretion in granting relief must be applied reasonably and compassionately.
These rulings confirm that CRA must apply the penalty and interest system with fairness, not force — and Mackisen makes sure they do.

Why CRA Issues Penalties

CRA’s 2025 penalty triggers are automated and unforgiving. Common reasons include:

  • Late personal or corporate tax filing.

  • Missed GST/HST or payroll remittances.

  • Unfiled T4, T5, or information slips.

  • Incorrect reporting or bookkeeping errors.

  • Auditor or accountant delays beyond your control.
    CRA assumes fault — Mackisen proves fairness and reason.

Mackisen’s Penalty Relief Strategy

  1. Penalty Review: Evaluate every penalty and identify where CRA misapplied or overcharged.

  2. Documentation & Evidence: Gather proof of illness, financial hardship, or professional error supporting relief.

  3. Taxpayer Relief Application: Draft and file a compelling Section 220(3.1) request grounded in law and jurisprudence.

  4. Negotiation & Advocacy: Communicate directly with CRA Relief Officers to ensure timely approval.

  5. Provincial Coordination: File equivalent relief requests with Revenu Québec for complete financial resolution.
    Our method ensures CRA acknowledges your good faith and cancels penalties that never should have existed.

Real Client Experience

A Montreal small business missed payroll remittances due to bank error and faced $68,000 in penalties. Mackisen documented the error and CRA cancelled 100% of the fines.
A Quebec professional was charged $42,000 in late filing interest while caring for a family emergency. Mackisen proved hardship and CRA waived all charges.

Common Questions

Can CRA cancel penalties for late filing or missed payments? Yes — Mackisen routinely secures full cancellation under Section 220(3.1).
Can CRA remove interest as well as penalties? Absolutely — CRA can forgive both if justified.
What qualifies as “extraordinary circumstances”? Illness, natural disasters, financial hardship, and professional error — Mackisen proves your eligibility.
How long does CRA take to decide? Typically 3–6 months — Mackisen accelerates processing through complete submissions.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leading experts in CRA Penalty and Interest Relief. Our CPA auditors and tax lawyers combine empathy with precision, helping clients restore fairness and rebuild confidence. We act fast, document thoroughly, and advocate fiercely — because life happens, and penalties shouldn’t destroy it. When CRA punishes mistakes, Mackisen delivers forgiveness.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Penalty Relief Consultation. The first meeting is free, and your protection starts immediately.

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