CRA Taxpayer Rights Audit 2025 — Defend Your Rights, Demand Fair Treatment, and Hold CRA Accountable with Mackisen CP

In 2025, CRA’s Taxpayer Rights Audit Initiative is under intense scrutiny as automation replaces human oversight. Many Canadians are being reassessed, penalized, or denied refunds without a fair review or explanation — a clear violation of their rights under the Taxpayer Bill of Rights. CRA systems now issue penalties automatically, freeze refunds, and reject relief requests without due process. At Mackisen CPA Auditors Montreal, we stand between you and unfair administration. Our CPA auditors and tax lawyers defend your rights, demand transparency, and ensure every CRA decision is legally justified. We don’t ask CRA for fairness — we enforce it.

Legal and Regulatory Framework

Taxpayer Bill of Rights (Canada)

• Right 1: To receive entitlements and pay no more and no less than what is required by law.

• Right 5: To be treated professionally, courteously, and fairly.

• Right 9: To have the law applied consistently.

• Right 11: To expect CRA to be accountable.

• Right 15: To lodge a complaint and have it reviewed impartially.
  Income Tax Act (Canada)

• Section 220(3.1): Allows CRA to grant penalty and interest relief through the Taxpayer Relief Program.

• Section 165(1): Grants every taxpayer the right to file a Notice of Objection against any reassessment.
  Tax Administration Act (Quebec)
  Revenu Québec enforces similar taxpayer protection standards. Mackisen coordinates both agencies to guarantee your rights are respected federally and provincially.

Key Court Decisions

Bédard v. The Queen (2022): CRA must act transparently and give taxpayers full disclosure during audits.
Thibault v. The Queen (2022): Fair treatment is mandatory under the Taxpayer Bill of Rights, not discretionary.
Guindon v. Canada (2015): Penalties are invalid if applied without due process or factual justification.
Venne v. The Queen (1984): CRA cannot act on assumption or bias when issuing reassessments.
These rulings confirm that CRA must treat taxpayers with fairness, accountability, and respect — or face reversal of its actions.

Why CRA Violates Taxpayer Rights

CRA’s automation and aggressive revenue goals have replaced case-by-case human review. Common 2025 violations include:

• Unexplained delays in refunds or relief.

• Denial of legitimate deductions without proof.

• Failure to provide evidence before reassessment.

• Automated penalty application without review.

• Ignoring taxpayer relief or hardship requests.
  CRA assumes authority — Mackisen enforces your legal rights.

Mackisen’s Taxpayer Rights Defense Strategy

1. Case Review: Identify every CRA violation of procedure, fairness, or law.

2. Formal Representation: File detailed objections citing the Taxpayer Bill of Rights and relevant court decisions.

3. Documentation Reconstruction: Collect evidence proving compliance and CRA administrative fault.

4. Appeals and Complaints: Escalate cases to CRA Appeals, the Taxpayers’ Ombudsperson, or Federal Court where required.

5. Penalty & Interest Relief: Apply under Section 220(3.1) to recover financial losses caused by CRA misconduct.
   Our representation ensures CRA accountability — not assumptions — governs your case.

Real Client Experience

A Montreal business owner’s refund was frozen for 14 months without explanation. Mackisen cited the Taxpayer Bill of Rights and CRA released the funds with interest.
A Quebec taxpayer was penalized for “unreported income” never verified by CRA. Mackisen challenged procedural fairness and CRA cancelled the entire reassessment.

Common Questions

What if CRA violates my rights? Mackisen files formal complaints and legal objections under the Taxpayer Bill of Rights.
Can CRA ignore my request for relief? No — failure to review fairly is a breach of law. Mackisen enforces accountability.
Can CRA delay my refund indefinitely? No — Mackisen compels immediate release through formal appeal or Federal Court action.
Can I recover damages from CRA? Yes — in cases of negligence or misconduct, Mackisen can seek compensation.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s voice for taxpayer justice. Our team combines the power of legal advocacy, accounting precision, and relentless negotiation to hold CRA accountable. We act swiftly, document thoroughly, and fight with conviction — because your rights are not optional. When CRA crosses the line, Mackisen draws it again.
Call Mackisen CPA Auditors Montreal today for your 2025 Taxpayer Rights Defense Consultation. The first meeting is free, and your protection starts immediately.