Insights
Oct 24, 2025
Mackisen

CRA Payment Arrangement 2025 — Stop Collections, Negotiate Affordable Payments, and Regain Financial Stability

If you owe money to the Canada Revenue Agency (CRA) or Revenu Québec, time is not your friend. In 2025, CRA’s automated collection systems track overdue tax accounts daily — issuing garnishments, bank freezes, and enforcement orders within days of missed deadlines. But you don’t have to face CRA alone. The law allows you to negotiate a payment arrangement, and with the right representation, you can stop collection immediately and pay your balance on your terms.
At Mackisen CPA Auditors Montreal, we specialize in securing fast, fair, and confidential CRA payment plans. Our CPA auditors and tax lawyers analyze your financial position, prepare detailed affordability assessments, and negotiate directly with CRA Collections Officers — protecting your income and assets. We handle both CRA and Revenu Québec cases, ensuring that all your tax accounts are synchronized under one manageable plan.
We don’t let CRA decide what you can pay — we help you decide what’s fair.
Legal and Regulatory Framework
Income Tax Act (Canada)
- Section 222: Treats unpaid taxes as a civil debt collectible by CRA. 
- Section 225.1: Allows CRA to issue Requirements to Pay (RTPs) to banks, employers, or clients. 
- Section 161(1): Interest accrues daily until the balance is paid in full or relief is approved. 
- Section 220(3.1): Authorizes CRA to reduce penalties and interest under the Taxpayer Relief Program for hardship cases. 
Tax Administration Act (Quebec)
Revenu Québec has matching authority to issue payment demands, garnishments, and liens, but also allows negotiated payment agreements for compliant taxpayers.
Mackisen manages both agencies concurrently, ensuring that your payments and relief requests align perfectly.
Key Court Decisions
Jordan v. The Queen (2009): CRA must act reasonably when negotiating repayment schedules.
Guindon v. Canada (2015): Penalties and interest may be cancelled under the relief program once a repayment plan is established.
Venne v. The Queen (1984): Tax debts remain valid, but CRA must allow reasonable opportunity to repay.
Browne v. The Queen (2022): Courts support taxpayers demonstrating financial hardship and cooperation with CRA.
These rulings confirm that cooperation and professional negotiation lead to better outcomes — and fewer penalties.
Why Payment Arrangements Are Critical
CRA’s collection tools are powerful — and immediate. Without a formal plan, CRA can:
- Freeze your personal or business bank accounts. 
- Garnish your wages or business receivables. 
- Register property liens and credit bureau notices. 
- Offset refunds or benefits automatically. 
Negotiating a payment arrangement through Mackisen stops these actions cold and replaces chaos with structure.
Mackisen’s CRA Payment Arrangement Strategy
- Financial Assessment: Review your full income, debt, and expense structure to determine realistic repayment capacity. 
- Collection Suspension: Contact CRA immediately to stop garnishments and enforcement actions. 
- Negotiation & Proposal: Present a detailed repayment plan backed by financial analysis and supporting documentation. 
- Taxpayer Relief Application: File for interest or penalty reduction under Section 220(3.1). 
- Ongoing Compliance Support: Maintain future tax filing and installment obligations to preserve your agreement. 
Our strategy ensures your payments are affordable, your accounts are protected, and CRA stays satisfied.
Real Client Experience
A Montreal small business owner faced a $127,000 CRA balance and a frozen account. Mackisen negotiated a 36-month structured repayment plan, lifting the freeze within 48 hours.
A Quebec freelancer with $42,000 in tax arrears was under wage garnishment. Mackisen’s proposal reduced monthly payments by 60% and secured penalty relief of $8,700.
Common Questions
Can CRA reject my payment plan? Yes, if it’s unrealistic or undocumented. Mackisen ensures your proposal is professionally structured and accepted.
Will interest stop once I start paying? No, but Mackisen can apply for interest relief under the Taxpayer Relief Program.
Can CRA collect while we negotiate? CRA can, but Mackisen requests an immediate hold on collections while terms are finalized.
Can I combine CRA and Revenu Québec payments? Yes — we coordinate both agencies for a single, synchronized plan.
Why Mackisen
At Mackisen CPA Auditors Montreal, we turn CRA pressure into financial peace. Our experts negotiate respectfully but firmly, ensuring that your rights are protected and your repayment plan is achievable.
We act quickly, decisively, and with your best interest at heart — because financial relief is not just possible; it’s your right.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Payment Arrangement Consultation. The first meeting is free, and your protection begins immediately.

