CRA Audit Collection Action 2025 — Stop Seizures, Garnishments, and CRA Harassment

When the Canada Revenue Agency (CRA) turns an audit into a collection case, the consequences can be immediate and severe. In 2025, CRA’s automated collection network can freeze bank accounts, seize business revenues, or garnish wages—all without court approval. For many Canadians, this happens after a reassessment or audit dispute that’s still unresolved. The CRA doesn’t wait for fairness; it acts for payment. But with fast, professional intervention, these actions can be stopped, reversed, and resolved legally.

At Mackisen CPA Auditors Montreal, we act immediately to protect your income, your assets, and your business from CRA enforcement. Our team of CPA auditors and tax lawyers negotiate directly with CRA collections officers to suspend garnishments, release bank accounts, and establish manageable repayment plans. We know CRA’s playbook—and how to outsmart it.

We don’t let CRA take control of your finances. We take control for you.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 222: Authorizes CRA to collect unpaid taxes as a civil debt.

• Section 225.1: Allows CRA to issue Requirements to Pay (RTPs) to banks, employers, or clients.

• Section 220(3.1): Permits penalty and interest relief through the Taxpayer Relief Program when hardship exists.

• Section 161(1): Interest compounds daily until the balance is paid or relief is approved.

Excise Tax Act (Canada)

• Section 315 & 316: Provide similar enforcement authority for unpaid GST/HST.

Tax Administration Act (Quebec)
Grants Revenu Québec matching powers to issue seizures, garnishments, and property liens for unpaid provincial taxes.

Mackisen manages both federal and Quebec collection files together—ensuring protection across all agencies.

Key Court Decisions

Venne v. The Queen (1984): CRA’s collection rights are enforceable but can be paused through formal dispute procedures.
Jordan v. The Queen (2009): CRA must follow due process when issuing garnishments or bank freezes.
Guindon v. Canada (2015): Relief can be granted for penalties and interest if taxpayer hardship is demonstrated.
Browne v. The Queen (2022): Courts favor taxpayers who show financial hardship and good faith efforts to comply.

These precedents prove that CRA’s power has limits—if you know how to invoke them.

Why CRA Launches Collection Actions

CRA collections typically begin when a balance remains unpaid following an audit, reassessment, or missed remittance. Common triggers include:

• Ignoring CRA correspondence or payment demands.

• Outstanding payroll or GST/HST remittances.

• Disputed tax balances with no objection filed.

• Unfiled tax returns flagged by CRA compliance systems.

• Missed installment or repayment agreements.

Once flagged, CRA can issue Requirements to Pay to banks or employers within hours, leaving you locked out of your accounts or short on payroll funds.

Mackisen’s CRA Collection Defense and Resolution Strategy

1. Immediate Intervention: Contact CRA within hours to request suspension of garnishments and bank freezes.

2. Debt Verification: Review CRA’s claim for calculation or assessment errors.

3. Negotiation and Settlement: Secure manageable repayment plans or temporary deferrals under hardship provisions.

4. Relief Application: File for penalty and interest cancellation under Section 220(3.1).

5. Long-Term Protection: Build proactive compliance and monitoring systems to prevent future collection escalation.

Our rapid-response team ensures you never face CRA alone—and never lose what you’ve built.

Real Client Experience

A Montreal entrepreneur woke up to find his corporate accounts frozen due to a $79,000 CRA balance. Mackisen intervened the same day, lifted the freeze within 24 hours, and negotiated a 36-month payment plan.
A Quebec construction firm faced simultaneous CRA and Revenu Québec garnishments. Mackisen consolidated both debts, filed a hardship-based relief request, and secured a 70% interest reduction.

Common Questions

Can CRA freeze my bank account without warning? Yes—but Mackisen can request an immediate release once a repayment plan is approved.
Can CRA collect while I dispute an audit? Not if a valid objection is filed. Mackisen ensures all legal protections are in place before CRA acts.
Can I negotiate directly with CRA? You can, but professionals achieve faster, safer results and protect your legal rights.
Does CRA target business owners personally? Yes—especially directors of corporations with payroll or GST arrears. Mackisen defends against personal liability.

Why Mackisen

At Mackisen CPA Auditors Montreal, we fight CRA’s most aggressive collection tactics with precision and authority. Our team of tax lawyers and CPAs works fast to stop enforcement actions, negotiate settlements, and restore control over your finances.

We act decisively, strategically, and with genuine care—because your business deserves protection, not punishment.

Call Mackisen CPA Auditors Montreal today for your 2025 CRA Collection Defense Consultation. The first meeting is free, and your protection begins immediately.