CRA Payroll Garnishment 2025 — Stop CRA From Seizing Employee Wages and Protect Your Business

A CRA payroll garnishment is every business owner’s nightmare. When the Canada Revenue Agency believes your company owes taxes — from payroll deductions, GST/HST, or reassessments — it can legally seize wages directly from your employees or clients without a court order. In 2025, CRA’s automated enforcement system makes this process instant: one click, and your staff’s pay or company’s cash flow can be frozen overnight. The damage goes far beyond your balance sheet — it affects your employees’ trust, your reputation, and your ability to operate.

At Mackisen CPA Auditors Montreal, we move immediately to stop payroll garnishments and protect your company from financial collapse. Our CPA auditors and tax lawyers contact CRA within hours, negotiate release of garnishment orders, and design affordable repayment plans that keep your business open and your staff paid.

We protect what you’ve built — your business, your people, your peace of mind.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 227.1: Holds corporate directors personally liable for unremitted payroll taxes.

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

• Section 222: Allows CRA to collect unpaid balances as civil debts without court authorization.

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

Tax Administration Act (Quebec)
Revenu Québec can also garnish employee wages, seize accounts, or intercept payments for unpaid QPP, QPIP, and payroll taxes — unless a valid objection or repayment plan is in place.

Mackisen handles both CRA and Revenu Québec payroll enforcement actions simultaneously to ensure your full protection.

Key Court Decisions

Buckingham v. The Queen (2011 FCA 142): Directors can be held personally liable for payroll tax remittance failures.
Jordan v. The Queen (2009): CRA must allow reasonable opportunity for compliance before garnishment.
Guindon v. Canada (2015): Penalties may be reduced through taxpayer relief when financial hardship is proven.
Thibault v. The Queen (2022): Courts expect CRA to consider proportionality and good faith in enforcement actions.

These cases show that CRA garnishments are not the end — they can be challenged and reversed when handled by professionals.

Why CRA Targets Payroll Garnishments

Payroll garnishments are one of CRA’s fastest ways to collect outstanding tax balances. The most common triggers in 2025 include:

• Unremitted source deductions (income tax, CPP, EI).

• Unpaid GST/HST or QST balances.

• Repeated non-compliance or ignored CRA correspondence.

• Defaulted payment plans or missed remittances.

• Ongoing tax disputes with unpaid reassessments.

Once a garnishment is issued, CRA can intercept wages, business receivables, or supplier payments — crippling operations in days.

Mackisen’s Payroll Garnishment Defense and Resolution Strategy

1. Immediate Action: Contact CRA within hours to suspend or revoke the garnishment order.

2. Debt Verification: Confirm CRA’s claim, correct calculation errors, and identify overpayments.

3. Payment Arrangement: Negotiate a structured and affordable repayment plan to stop enforcement.

4. Director Protection: File defense documentation to prevent personal liability under Section 227.1.

5. Taxpayer Relief Filing: Submit applications for penalty and interest reduction under Section 220(3.1).

Our experts use accounting evidence and legal reasoning to ensure your operations stay intact and CRA enforcement stops immediately.

Real Client Experience

A Montreal retailer’s payroll was seized after CRA issued a $114,000 garnishment order. Mackisen intervened the same day, suspended enforcement, and negotiated a 24-month payment arrangement that saved the business.
A Quebec manufacturing company had multiple employee wage garnishments due to unpaid source deductions. Mackisen proved administrative error and achieved a full release of garnishment within 48 hours.

Common Questions

Can CRA garnish employee wages directly from my payroll? Yes — but Mackisen can intervene immediately to lift or suspend the order.
Are directors personally liable? Yes, for unremitted payroll deductions, unless due diligence can be proven. Mackisen builds this defense.
Can CRA garnish wages while I dispute the debt? Not if an objection or appeal is filed — Mackisen ensures legal protection is in place.
How can I prevent future payroll garnishments? By establishing structured remittance schedules and compliance plans — which Mackisen implements for every client.

Why Mackisen

At Mackisen CPA Auditors Montreal, we combine legal insight and financial expertise to protect your business from CRA’s most damaging actions. Our firm acts fast, negotiates confidently, and rebuilds compliance systems that keep your company safe long-term.

We don’t just defend your business — we preserve your future.

Call Mackisen CPA Auditors Montreal today for your 2025 Payroll Garnishment Defense Consultation. The first meeting is free, and your protection starts immediately.