CRA Taxpayer Rights 2025 — Know the Law, Protect Yourself, and Hold CRA Accountable with Mackisen CPA

CRA’s enforcement programs are more powerful and automated than ever, but most Canadians don’t realize that they have legally protected taxpayer rights. CRA is required by law to treat every taxpayer with fairness, transparency, and respect under the Taxpayer Bill of Rights. Yet, many individuals and business owners experience aggressive audits, delayed refunds, and unjust penalties because they don’t understand how to assert those rights. At Mackisen CPA Auditors Montreal, we make sure CRA follows the law. Our CPA auditors and tax lawyers protect clients from unfair treatment, enforce due process, and secure relief through formal appeals and taxpayer relief applications. We don’t let CRA’s systems intimidate or overreach — we make sure they play by the rules.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 165(1): Provides the right to dispute any CRA reassessment through a formal Notice of Objection. Section 220(3.1): Establishes the right to request cancellation or reduction of penalties and interest through the Taxpayer Relief Program. Section 241(1): Protects taxpayer confidentiality and restricts unauthorized CRA disclosure. Section 225.1(1): Restricts CRA collections during active disputes or appeals. Section 152(4): Limits CRA’s ability to reassess returns to within three years unless misrepresentation or fraud is proven.
Taxpayer Bill of Rights The Taxpayer Bill of Rights guarantees 16 core protections, including the right to fair treatment, professional service, privacy, explanation, appeal, and independent review by the Office of the Taxpayers’ Ombudsperson. Mackisen ensures every one of these rights is respected in your case.

Key Court Decisions

Bédard v. The Queen (2022): CRA must exercise fairness and transparency during all audits and appeals. Thibault v. The Queen (2022): Taxpayers have the right to an unbiased review of reassessments. Guindon v. Canada (2015): Penalties cannot be imposed without clear evidence of intent. Jordan v. The Queen (2009): CRA’s treatment of taxpayers must reflect procedural fairness and proportionality. These cases confirm that taxpayers can challenge CRA not only on taxes owed but also on how they are treated.

Why Knowing Your Rights Matters

CRA’s automated enforcement systems can freeze accounts, reassess taxes, and apply penalties instantly. Without understanding your rights, it’s easy to accept unfair treatment or miss deadlines for appeal. Common 2025 issues include ignored objections, unauthorized collections during disputes, or privacy breaches. CRA assumes compliance is one-way — Mackisen enforces balance and accountability.

Mackisen’s Taxpayer Rights Protection Strategy

1. Legal Rights Review: Analyze all CRA correspondence and determine if your taxpayer rights have been violated. 2. File Objections and Appeals: Challenge improper reassessments through the CRA Appeals Division or Tax Court of Canada. 3. Request Relief: File under Section 220(3.1) to cancel penalties caused by CRA delay or administrative error. 4. Ombudsperson Referral: Escalate unresolved fairness complaints to the Office of the Taxpayers’ Ombudsperson. 5. Prevent Retaliation: Ensure future CRA interactions remain compliant with the Taxpayer Bill of Rights. Mackisen ensures your rights are defended at every step and your voice is heard at every level.

Real Client Experience

A Montreal restaurant owner had their refund withheld for nine months without explanation. Mackisen filed a fairness complaint and CRA released the full amount plus interest. A Quebec consultant was penalized twice for a single filing error. Mackisen cited procedural unfairness and CRA cancelled the penalty in full.

Common Questions

Can I dispute how CRA treated me? Yes, Mackisen can file a formal fairness complaint and escalate through legal channels. Can CRA collect money while I appeal? No, CRA is prohibited from collections during valid objections or appeals. Can CRA share my tax information with others? No, Mackisen enforces strict taxpayer confidentiality rights under Section 241. Can I get compensation for CRA errors? Yes, Mackisen can request interest reimbursement or administrative relief under the Taxpayer Relief Program.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s defenders of taxpayer fairness and legal protection. Our integrated team of CPAs and tax lawyers ensures your rights are respected, your file is handled justly, and CRA is held accountable. We act fearlessly, respond intelligently, and fight relentlessly — because fairness is not optional, it’s your legal right. When CRA crosses the line, Mackisen draws it back. Call Mackisen CPA Auditors Montreal today for your 2025 Taxpayer Rights Consultation. The first meeting is free, and your protection starts immediately.