Tax Dispute

Stop penalties, protect your cash flow, and resolve tax problems fast.
If you’ve received a CRA or Revenu Québec audit letter, reassessment, or collection notice, you don’t have to face it alone. Mackisen’s tax lawyers + CPAs work together to defend you, negotiate payment arrangements, apply for taxpayer relief (penalties & interest), and, when needed, coordinate consumer proposals or bankruptcy options. We serve Montreal, Quebec, and clients across Canada.

What We Do (End-to-End Defense & Resolution)

1) CRA/ARQ Audit Defense
Full representation for income tax, GST/QST, payroll/source deductions audits. We handle auditor communications, document requests, and on-site/virtual meetings; organize records, verify income & expenses, and rebut incorrect assumptions. Outcome: a smaller adjustment—or none at all.

2) Objections & Appeals (Reassessments)
Disagree with a notice of reassessment? We draft objections (strict deadlines apply), prepare evidence, and escalate to appeals if needed. Where warranted, we negotiate a fair settlement before it goes further.

3) Voluntary Disclosures (VDP) — Undeclared Income
Unreported income (cash, crypto, gig work), missed slips, or late filings? We prepare a Voluntary Disclosure to correct the record and significantly reduce penalties (and avoid prosecution).

4) Taxpayer Relief — Penalties & Interest
If penalties/interest are crushing your budget, we file Taxpayer Relief applications (CRA/ARQ) for cancellation/waiver due to financial hardship, extraordinary circumstances, or agency error—backed by evidence.

5) Collections & Enforcement: Frozen Bank Accounts / Garnishments
Account frozen? Wage garnishment, liens, demands to pay? We contact Collections to seek an immediate hold, then arrange a realistic payment plan while we correct the file.

6) Payment Arrangements & Settlements
We negotiate structured payment plans you can afford; sequence instalments; and balance cash flow with compliance so you stay current and avoid further enforcement.

7) Books & Records Reconstruction
Missing receipts? Incomplete records? We rebuild ledgers from bank statements, invoices, POS data—so the audit is supported and undeclared income assumptions are challenged with facts.

8) GST/QST, Payroll & Source Deductions Audits
We resolve GST/HST/QST and payroll audits (CPP/EI, source remittances). We prove ITCs, correct coding, and settle arrears with manageable terms—preventing director-liability escalation.

9) Director Liability & Personal Risk
We defend against personal assessments on directors for unremitted source deductions or GST/QST, manage timelines, and build evidence to minimize exposure.

10) Consumer Proposal / Bankruptcy Coordination
When debts exceed capacity, we coordinate consumer proposals (individual) or corporate reorganizations/bankruptcies with Licensed Insolvency Trustees—supplying tax schedules and negotiating stays.

11) Audit Readiness & Triage (24–48h)
Rapid intake: letter review, risk map, document checklist, and step-by-step plan plus a hold request to Collections if needed.

12) Post-Audit Compliance Coaching
We fix root causes (bookkeeping, invoicing, GST/QST coding, payroll cycles) so issues don’t repeat—and establish a calendar for on-time filings.

Benefits of Professional Representation

• Lower balances: Reduce assessed income, disallowances, penalties & interest

• Fewer disruptions: We manage auditors and Collections to protect your time & cash flow

• Faster resolution: Immediate triage, clear timelines, structured settlement options

• Stress off your plate: A single team (tax lawyers + CPAs) from audit to appeal

Why Choose Mackisen for Tax Disputes?

• In-house tax lawyers + CPAs: Legal and accounting firepower in one place

• Quebec + Federal expertise: CRA and Revenu Québec rules, bilingual service

• Fast response: Triage within 24–48 hours for urgent letters/frozen accounts

• Proven processes: Objections, appeals, VDP, relief, and payment plans—end-to-end

• Local presence, national reach: Based in Montréal, Quebec, serving clients across Canada