Insights
Oct 23, 2025
Mackisen
CRA Requirement To Pay Notices 2025
Imagine waking up to discover your bank account frozen or your employer withholding part of your paycheck—not because of your actions, but because of a CRA Requirement to Pay (RTP). In 2025, the CRA’s collection technology is faster and more aggressive than ever, allowing it to seize your money directly through financial institutions, clients, or employers—without going to court. The RTP is one of CRA’s most powerful enforcement tools, and it can strike without warning.
When CRA issues a Requirement to Pay, they legally compel third parties—banks, employers, or anyone who owes you money—to redirect your funds to them. This can instantly disrupt your business operations, family finances, or payroll. Most Canadians are shocked to learn that CRA doesn’t need your permission—or even your cooperation—to act. But with immediate professional intervention, you can stop the freeze, negotiate relief, and regain access to your funds before irreversible damage is done.
At Mackisen CPA Auditors Montreal, we specialize in defending individuals and businesses against CRA enforcement. Our CPA auditors and tax lawyers act fast to lift RTP orders, negotiate structured payment solutions, and restore access to your income and accounts—legally, efficiently, and with absolute discretion.
Legal and Regulatory Framework
Income Tax Act (Canada)
Section 224(1): Authorizes CRA to issue Requirements to Pay to any third party (e.g., bank, employer, customer) who owes or holds money on behalf of a taxpayer.
Section 225.1: Allows CRA to enforce RTPs without prior court authorization.
Section 161(1): Interest continues to accrue on the unpaid amount until settled.
Section 220(3.1): Allows relief or reversal of penalties and interest through the Taxpayer Relief Program in cases of financial hardship.
Tax Administration Act (Quebec)
Revenu Québec has parallel authority to issue third-party garnishment notices, freezing accounts or intercepting income at the provincial level.
Mackisen intervenes directly with CRA and Revenu Québec collections officers to suspend RTPs, challenge their validity, and negotiate affordable repayment solutions.
Key Court Decisions
Guindon v. Canada (2015): CRA enforcement powers, including RTPs, are legally enforceable unless successfully appealed.
Jordan v. The Queen (2009): CRA interest and penalties continue to accumulate during enforcement, emphasizing the urgency of action.
Wells v. The Queen (2011): Demonstrated that taxpayers can challenge improper RTP issuance through formal representation.
These cases confirm that while RTPs are legal, they are not unchallengeable—and professional representation can make the difference between financial crisis and recovery.
Why Requirement to Pay Notices Are So Dangerous
CRA RTPs are designed for speed, not fairness. They’re issued electronically and take effect immediately upon receipt by the third party—often before you even know they exist. Their consequences can include:
Frozen bank accounts, making it impossible to pay bills or suppliers.
Wage garnishments, reducing your income by up to 50%.
Intercepted receivables, crippling your business cash flow.
Loss of reputation or credit damage from public enforcement actions.
Once funds are remitted to CRA, they’re nearly impossible to recover without formal dispute or relief. Timing and expertise are everything.
Mackisen’s Requirement to Pay Defense and Resolution Strategy
Immediate CRA Communication: Contact CRA and Revenu Québec collections within hours to halt or suspend enforcement.
Account Verification: Review the legality of the RTP and confirm whether CRA followed correct procedures.
Negotiation and Payment Plan: Establish an affordable, compliant installment plan to lift the RTP.
Financial Hardship Relief: File for interest and penalty reduction under the Taxpayer Relief Program.
Preventive Compliance: Build a long-term strategy to ensure your accounts and payroll remain protected from future RTPs.
Our rapid-response process is designed to stop enforcement within 24–48 hours, restoring access to your income and accounts while we negotiate sustainable solutions.
Real Client Experience
A Montreal business owner had their operating account frozen after CRA issued an RTP to their bank for $72,000. Mackisen intervened within 24 hours, secured partial fund release, and negotiated a structured payment plan—saving the company from insolvency.
A professional consultant’s wages were garnished due to a past tax balance of $38,000. Mackisen negotiated immediate relief, filed a hardship-based relief application, and reduced total interest by 40%.
Common Questions
Can CRA freeze my account without warning? Yes, but Mackisen can contact CRA to lift the freeze once a payment arrangement is reached.
Can my employer refuse to comply with an RTP? No—employers are legally obligated to send payments to CRA or face penalties themselves.
Can I challenge a Requirement to Pay? Yes, through professional representation and, if necessary, legal objection or appeal.
How can I prevent future RTPs? By establishing a compliance plan, managing timely filings, and maintaining communication with CRA—services Mackisen provides proactively.
Why Mackisen
At Mackisen CPA Auditors Montreal, we don’t wait for the CRA to dictate the outcome—we take control of it. Our audit, tax, and legal teams specialize in stopping enforcement actions quickly and protecting clients from financial damage.
We work with precision, professionalism, and compassion—because when the CRA freezes your money, what you need most is a team that can unfreeze your future.
Call Mackisen CPA Auditors Montreal today for your 2025 CRA Requirement to Pay Defense Consultation. The first meeting is free, and your protection begins immediately.
