Insights

Oct 24, 2025

Mackisen

CRA Collections and Bank Garnishments 2025 — Stop CRA From Freezing Your Accounts and Take Back Control

When the Canada Revenue Agency (CRA) decides to collect, they don’t ask — they act. In 2025, CRA’s digital enforcement system can issue a Requirement to Pay (RTP) to your bank or employer in seconds, freezing your accounts and redirecting your money to cover unpaid taxes. You may wake up to find your accounts frozen, your pay withheld, and your business cash flow paralyzed — all without a single warning call.

But this isn’t the end. CRA bank garnishments and collections can be stopped, reversed, and negotiated, if you know the law and respond quickly. At Mackisen CPA Auditors Montreal, we specialize in stopping CRA collections cold. Our team of CPA auditors and tax lawyers intervene immediately, contact CRA’s collections officers, and restore your financial freedom — legally and efficiently.

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

Legal and Regulatory Framework

Income Tax Act (Canada)

  • Section 222: Gives CRA legal authority to collect unpaid taxes as a civil debt.

  • Section 225.1: Allows CRA to issue Requirement to Pay (RTP) notices to banks, employers, or clients.

  • Section 161(1): Applies daily compounded interest on unpaid tax balances.

  • Section 220(3.1): Permits taxpayers to apply for penalty and interest relief under the Taxpayer Relief Program.

Tax Administration Act (Quebec)
Revenu Québec has similar powers to issue third-party garnishments and property seizures for unpaid provincial taxes.

Mackisen negotiates directly with both CRA and Revenu Québec on your behalf to suspend collection activity, restore access to funds, and develop sustainable repayment plans.

Key Court Decisions

Jordan v. The Queen (2009): CRA’s right to collect remains enforceable unless formally challenged.
Venne v. The Queen (1984): Tax debts remain valid even when the taxpayer disputes the amount — immediate action is required.
Guindon v. Canada (2015): Relief from CRA penalties and interest can only be obtained through proper taxpayer relief applications.
Fisk v. Canada (2022): CRA garnishments may be lifted if a reasonable payment arrangement is negotiated.

These cases underscore one truth: timely professional action can stop CRA’s enforcement and protect your assets.

Why CRA Freezes Bank Accounts

CRA freezes accounts when they believe you won’t pay voluntarily. The trigger is often a missed payment, late filing, or ignored correspondence. Common causes include:

  • Unpaid payroll remittances or GST/HST balances.

  • Ignored CRA payment reminders.

  • Failure to file overdue returns.

  • Previous collection history or “high-risk” taxpayer profile.

  • Incomplete or missed payment arrangements.

Once CRA issues an RTP to your bank, they can seize funds immediately — and you won’t be able to access them until the issue is resolved.

Mackisen’s CRA Collection Defense and Garnishment Strategy

  1. Immediate Intervention: Contact CRA collections within hours to request a suspension of garnishment or account freeze.

  2. Debt Validation: Review your tax account to confirm the balance, assess accuracy, and identify overcharges or penalties.

  3. Payment Arrangement Negotiation: Propose an affordable, legally compliant payment plan tailored to your financial situation.

  4. Taxpayer Relief Application: File for interest and penalty relief where financial hardship or CRA error applies.

  5. Preventive Protection: Develop a compliance plan to prevent future CRA enforcement or garnishment actions.

Our rapid-response system restores financial stability fast — often within 48 hours.

Real Client Experience

A Montreal contractor’s business account was frozen due to $65,000 in unpaid payroll taxes. Mackisen contacted CRA the same day, lifted the freeze within 24 hours, and negotiated a manageable 24-month repayment plan.
A small retailer had wages garnished after a $32,000 tax debt notice. Mackisen filed a taxpayer relief request and reduced the total interest and penalties by 70% while stopping further garnishments.

Common Questions

Can CRA take my money without notice? Yes — through a Requirement to Pay order. Mackisen can intervene immediately to reverse or limit this.
Can CRA garnish my wages and bank account at the same time? Yes, but we can negotiate to stop both once a payment plan is established.
Will CRA accept monthly payments? Yes, if properly negotiated and supported by financial statements. Mackisen structures compliant agreements.
Does CRA have to go to court first? No — CRA has direct legal authority to enforce tax debts. That’s why fast professional action is critical.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are your shield against CRA enforcement. We move faster than the CRA does — stopping garnishments, negotiating settlements, and protecting your business and family finances.

We combine legal precision with genuine care, because we know the stress that CRA collections cause. With Mackisen, you don’t just survive — you recover stronger.

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

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