CRA Taxpayer Relief Application 2025 — Cancel Penalties, Reduce Interest, and Restore Fairness with Mackisen CPA

In 2025, CRA’s Taxpayer Relief Program has become the most powerful tool for Canadians seeking justice after unfair penalties, reassessments, or audit outcomes. Every year, thousands of taxpayers — individuals, small businesses, and corporations — face devastating penalties and interest for situations beyond their control: illness, bookkeeping errors, CRA delays, or professional misadvice. Most never realize they can request full relief. At Mackisen CPA Auditors Montreal, we specialize in building successful Taxpayer Relief Applications that stop CRA collection, cancel interest, and restore financial fairness. Our CPA auditors and tax lawyers combine strategic documentation with precise legal argumentation to achieve results other firms can’t. We don’t just request relief — we get it approved.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 220(3.1): Authorizes CRA to waive or cancel penalties and interest in cases of exceptional circumstances.

• Section 152(4): Defines reassessment timelines and exceptions for relief eligibility.

• Section 165(1): Allows filing of objections that support relief claims.

• CRA IC07-1R1 (Taxpayer Relief Guidelines): Provides administrative rules for relief due to hardship, error, or delay.
  Tax Administration Act (Quebec)
  Revenu Québec offers a parallel relief program for provincial penalties and interest. Mackisen coordinates both submissions to ensure complete financial recovery.

Key Court Decisions

Guindon v. Canada (2015): Good faith and reliance on professional advice negate gross negligence penalties.
Bédard v. The Queen (2022): CRA must consider individual hardship and fairness when evaluating relief requests.
Thibault v. The Queen (2022): Evidence of due diligence and communication supports full interest cancellation.
Jordan v. The Queen (2009): CRA administrative delays justify retroactive penalty elimination.
These rulings confirm that CRA must act fairly and cannot deny relief when reasonable cause exists.

Why CRA Denies Relief Requests

CRA rejects thousands of applications each year because they’re incomplete or lack supporting evidence. Common 2025 denial triggers include:

• Generic or unsupported explanations.

• Missing documentation for illness, hardship, or professional error.

• Late submissions beyond the 10-year limitation period.

• Inconsistent financial or communication records.
  CRA assumes non-eligibility — Mackisen proves exceptional circumstances.

Mackisen’s Taxpayer Relief Application Strategy

1. Eligibility Review: Analyze CRA assessments, interest calculations, and relief time limits.

2. Evidence Compilation: Gather financial, medical, or professional documentation to substantiate your claim.

3. Narrative and Legal Framing: Draft a compelling relief letter based on hardship, error, or exceptional events.

4. Formal Submission: File complete applications federally and provincially, ensuring procedural compliance.

5. Appeal and Follow-Up: Escalate denied applications to CRA Appeals or Federal Court when necessary.
   Our proven process has secured millions in cancelled penalties and refunded interest for Canadian taxpayers.

Real Client Experience

A Montreal entrepreneur owed $268,000 in CRA interest after pandemic delays. Mackisen demonstrated financial hardship and secured full interest cancellation.
A Quebec medical corporation was charged $94,000 in payroll penalties after an accountant’s error. Mackisen proved reasonable reliance and CRA eliminated the entire penalty.

Common Questions

Can CRA cancel both penalties and interest? Yes — Mackisen applies under Section 220(3.1) to remove both when justified.
Is there a deadline for applying? Yes — CRA accepts relief applications within 10 years of the tax year in question.
What if CRA has already started collections? Mackisen can pause collection while your relief request is processed.
Can I apply even after paying the penalty? Yes — CRA can refund cancelled penalties or interest upon approval.

Why Mackisen

At Mackisen CPA Auditors Montreal, we combine deep legal expertise with compassionate representation. We understand that tax penalties often result from life’s disruptions, not misconduct. Our firm fights for fairness with precision, credibility, and results. We act fast, argue firmly, and deliver relief that restores financial peace of mind. When CRA enforces penalties, Mackisen enforces fairness.
Call Mackisen CPA Auditors Montreal today for your 2025 Taxpayer Relief Consultation. The first meeting is free, and your recovery starts immediately.