Insights
Oct 24, 2025
Mackisen

CRA Taxpayer Relief Application 2025 — Cancel Penalties, Reduce Interest, and Restore Financial Stability

When life’s challenges cause tax delays, the CRA doesn’t wait—but the law gives you a second chance. Under the Taxpayer Relief Program, you can request full or partial cancellation of CRA penalties and interest caused by hardship, illness, or honest error. In 2025, this program is more crucial than ever as CRA’s automated systems issue penalties instantly, often without considering your personal or financial situation.
Unfortunately, most applications are denied because they’re poorly written, lack supporting evidence, or fail to cite the right legal provisions. At Mackisen CPA Auditors Montreal, we build winning Taxpayer Relief Applications that demonstrate hardship, prove compliance intent, and meet every CRA and Revenu Québec requirement. Our CPA auditors and tax lawyers use strategic evidence presentation to secure relief for individuals and businesses who deserve fairness.
We don’t beg for relief — we prove you’ve earned it.
Legal and Regulatory Framework
Income Tax Act (Canada)
- Section 220(3.1): Grants CRA authority to cancel or waive penalties and interest in exceptional circumstances. 
- Section 161(1): Applies daily interest on unpaid taxes until relief is approved. 
- Information Circular IC07-1R1: Defines CRA’s administrative guidelines for the Taxpayer Relief Program. 
Tax Administration Act (Quebec)
Revenu Québec offers a parallel relief mechanism that allows for cancellation of provincial interest and penalties due to financial hardship, administrative error, or force majeure.
Mackisen prepares and submits federal and provincial relief applications together, ensuring accuracy and consistency across both agencies.
Key Court Decisions
Guindon v. Canada (2015): Penalties are valid unless successfully overturned through relief or appeal.
Browne v. The Queen (2022): CRA must consider fairness and taxpayer circumstances when reviewing relief requests.
Campbell v. The Queen (2017): Documented financial hardship is a valid ground for interest and penalty cancellation.
Jordan v. The Queen (2009): CRA must provide reasons when denying taxpayer relief, allowing taxpayers to reapply.
These precedents confirm that strong evidence and professional representation are the foundation of a successful relief case.
When to File a Taxpayer Relief Application
You should file for taxpayer relief if you’ve faced any of the following:
- Serious illness, accident, or family death impacting your ability to file or pay. 
- Financial hardship due to job loss, business failure, or natural disaster. 
- CRA administrative error or processing delay. 
- Circumstances beyond your control (e.g., pandemic, cyber breach, or major system error). 
- Emotional or financial stress preventing timely compliance. 
Mackisen ensures your request demonstrates both legitimacy and empathy—backed by factual, organized documentation.
Mackisen’s Taxpayer Relief Strategy
- Eligibility Analysis: Evaluate your full CRA and Revenu Québec history to confirm qualification. 
- Evidence Compilation: Gather financial records, correspondence, and hardship documentation. 
- Professional Submission: Draft a clear, persuasive application citing legal grounds and supporting jurisprudence. 
- Negotiation and Follow-Up: Communicate directly with CRA’s Relief Division to expedite review and respond to queries. 
- Appeal Filing (if denied): Reapply or escalate your case with additional documentation and legal arguments. 
Our approach ensures your story is told clearly, professionally, and powerfully — in the language CRA listens to.
Real Client Experience
A Montreal entrepreneur incurred $74,000 in penalties after illness prevented filing on time. Mackisen filed a hardship-based Taxpayer Relief Application with supporting medical documentation — CRA cancelled 100% of penalties and interest.
A Quebec family business was penalized for late payroll remittances due to a flood. Mackisen proved the disaster’s impact, securing a full interest waiver and a flexible repayment plan.
Common Questions
How far back can CRA grant relief? Up to 10 years from the end of the taxation year.
Does CRA ever reject relief applications? Yes—most are denied for lack of evidence or incomplete documentation. Mackisen prevents this by preparing fully substantiated cases.
Can I apply for both CRA and Revenu Québec relief? Yes, and Mackisen prepares both concurrently for maximum success.
Will CRA stop collections while reviewing my relief? It may, depending on financial hardship—our team negotiates to suspend enforcement where applicable.
Why Mackisen
At Mackisen CPA Auditors Montreal, we turn “no” into “yes” by building tax relief applications that meet the highest legal and evidentiary standards. Our team’s deep understanding of CRA policy and judicial precedent ensures that every submission tells your story with strength and credibility.
We don’t ask CRA for compassion—we compel them to apply fairness. With Mackisen, your relief isn’t a request—it’s a right.
Call Mackisen CPA Auditors Montreal today for your 2025 Taxpayer Relief Consultation. The first meeting is free, and your recovery starts immediately.

