Insights
Oct 24, 2025
Mackisen
CRA Bank Freeze 2025 — Unfreeze Your Accounts, Stop CRA Enforcement, and Protect Your Finances
Imagine waking up to discover your bank account is frozen — no access to your money, payroll blocked, suppliers unpaid. This is the reality thousands of Canadians face each year when the Canada Revenue Agency (CRA) issues a Requirement to Pay (RTP). In 2025, CRA’s collection systems are fully automated, meaning your account can be seized overnight for unpaid taxes, even if you’re in the middle of a dispute or waiting for relief. But with immediate professional intervention, your accounts can be unfrozen, your business saved, and your reputation protected.
At Mackisen CPA Auditors Montreal, we act within hours to reverse CRA bank freezes. Our CPA auditors and tax lawyers contact CRA collections, verify the balance, and negotiate legal releases — ensuring you regain access to your funds fast. We also restructure your tax position to prevent future freezes, secure repayment terms, and protect your assets from seizure.
We don’t let CRA control your money — we help you take control back.
Legal and Regulatory Framework
Income Tax Act (Canada)
Section 225.1: Authorizes CRA to issue Requirements to Pay to banks or third parties holding funds on behalf of a taxpayer.
Section 222: Establishes CRA’s power to collect tax debts as civil obligations.
Section 220(3.1): Provides authority for Taxpayer Relief to cancel interest and penalties in hardship cases.
Section 161(1): Adds daily compounded interest until the balance is resolved or suspended.
Tax Administration Act (Quebec)
Gives Revenu Québec the same powers to freeze bank accounts or issue third-party seizures — but also allows account releases when a formal payment plan or appeal is in place.
Mackisen manages both CRA and Revenu Québec freezes simultaneously, coordinating rapid resolutions across jurisdictions.
Key Court Decisions
Venne v. The Queen (1984): CRA’s enforcement powers are valid but can be challenged when applied without due process.
Jordan v. The Queen (2009): CRA must allow reasonable negotiation opportunities before freezing accounts.
Guindon v. Canada (2015): Taxpayer relief may apply when CRA’s enforcement causes undue hardship.
Browne v. The Queen (2022): Courts favor taxpayers who act quickly and file formal objections or relief requests.
These cases confirm that speed and professional representation are your best defense against CRA enforcement.
Why CRA Freezes Bank Accounts
CRA uses bank freezes to force payment or compliance when other collection methods fail. Common 2025 triggers include:
Unpaid personal or business tax balances.
Ignored CRA letters, demands, or notices.
Outstanding payroll, GST/HST, or QST remittances.
Failure to respond to audit reassessments.
Missed installment or payment arrangements.
Once a Requirement to Pay is issued, banks must legally hold and remit your funds to CRA — often within 24 hours — unless an intervention occurs.
Mackisen’s Bank Freeze Defense and Resolution Strategy
Immediate Intervention: Contact CRA collections the same day to request a temporary freeze release.
Verification & Recalculation: Review CRA’s balance for duplicate, outdated, or inaccurate assessments.
Negotiation & Payment Plan: Secure an affordable repayment schedule or formal objection to suspend enforcement.
Relief Application: File a Taxpayer Relief request under Section 220(3.1) to reduce interest and penalties.
Future Protection: Set up compliance and monitoring systems to prevent future freezes or garnishments.
Our goal: get your accounts unfrozen within 24–48 hours and protect you from future CRA action.
Real Client Experience
A Montreal contractor’s operating account was frozen for $92,000 in unpaid payroll taxes. Mackisen intervened immediately, secured a partial release within 12 hours, and negotiated a structured 24-month repayment plan.
A Quebec consulting firm had multiple accounts seized by CRA and Revenu Québec simultaneously. Mackisen proved financial hardship and secured a full release of funds within 48 hours while negotiating reduced interest.
Common Questions
How long does a CRA bank freeze last? Until the full balance is paid or CRA agrees to release it. Mackisen negotiates rapid resolutions.
Can CRA freeze joint accounts? Yes — even if the other holder has no tax debt. Mackisen can challenge and reverse this.
Can my bank refuse to release funds? No — once CRA approves a release, the bank must comply immediately.
Can I stop CRA from freezing my accounts again? Yes — through a formal payment arrangement and consistent compliance.
Why Mackisen
At Mackisen CPA Auditors Montreal, we combine speed, authority, and experience to resolve CRA freezes quickly and effectively. We know that every hour without access to funds can threaten your livelihood — and we treat your case with urgency and respect.
We act fast, fight hard, and protect what you’ve earned. With Mackisen, your accounts are not just unfrozen — your financial freedom is restored.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Bank Freeze Emergency Consultation. The first meeting is free, and we act immediately.
