CRA Tax Collection Appeal 2025 — Stop CRA Actions, Reverse Garnishments, and Protect Your Finances

In 2025, CRA’s Tax Collections Division has adopted one of the most aggressive enforcement strategies in Canadian history. Using digital automation, CRA can now freeze your bank account, garnish your wages, or seize your assets — without a court order. Many taxpayers are facing financial chaos after receiving “Requirement to Pay” notices they didn’t even understand. But you have legal rights, and CRA’s power can be challenged. At Mackisen CPA Auditors Montreal, we stop CRA collections fast. Our CPA auditors and tax lawyers file immediate Tax Collection Appeals, negotiate structured settlements, and eliminate penalties under the Taxpayer Relief Program. We don’t let CRA’s tactics destroy your business or family finances — we defend your dignity, your rights, and your stability.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 224(1): Authorizes CRA to issue a Requirement to Pay (RTP) to seize wages or bank funds — Mackisen stops these orders through formal objection.

• Section 225.1(1): Defines CRA’s collection authority but suspends enforcement once a Notice of Objection is filed.

• Section 220(3.1): Allows CRA to cancel or reduce penalties and interest through the Taxpayer Relief Program.

• Section 165(1): Grants taxpayers the right to object to CRA’s actions and initiate formal appeals.
  Tax Administration Act (Quebec)
  Revenu Québec holds similar enforcement powers but must comply with due process. Mackisen coordinates both agencies to stop parallel collection efforts and secure immediate financial relief.

Key Court Decisions

Bédard v. The Queen (2022): CRA must act fairly and proportionally when enforcing collection orders.
Thibault v. The Queen (2022): Taxpayers have the right to negotiate payment terms and prevent unnecessary hardship.
Guindon v. Canada (2015): Honest reporting and professional reliance negate grounds for aggressive enforcement.
Jordan v. The Queen (2009): CRA’s collection actions can be overturned if they violate procedural fairness.
These decisions confirm that CRA’s collection power is not absolute — it can and must be challenged when it’s unfair or excessive.

Why CRA Targets Taxpayers for Collection

CRA uses AI-driven risk scoring to identify taxpayers with outstanding balances. Common 2025 triggers include:

• Unpaid income tax or GST/HST after reassessment.

• Missed payment arrangements or delayed filings.

• Corporate payroll or source deduction arrears.

• Unresolved audit disputes without formal objection.

• Ignored CRA correspondence or expired payment deadlines.
  CRA assumes default — Mackisen proves cooperation and capacity.

Mackisen’s Tax Collection Defense Strategy

1. Immediate Action: Contact CRA Collections to stop ongoing garnishments or bank freezes.

2. Verification & Audit Review: Confirm the accuracy and validity of the tax debt claimed.

3. Formal Objection Filing: Submit a Notice of Objection to suspend all collection activity.

4. Negotiation & Settlement: Arrange a fair, interest-free payment plan or reduced balance settlement.

5. Taxpayer Relief Application: File under Section 220(3.1) to cancel penalties and interest.
   Our method halts CRA’s aggressive tactics and restores your financial breathing room.

Real Client Experience

A Montreal professional had 40% of their wages garnished for unpaid tax debt. Mackisen filed an appeal and CRA lifted the garnishment within 72 hours.
A Quebec logistics company had its operating account frozen due to GST arrears. Mackisen proved procedural error and CRA released all funds immediately.

Common Questions

Can CRA seize my assets without warning? Yes — but Mackisen can stop the seizure through immediate appeal or negotiation.
Can CRA freeze my joint bank account? Yes, if your name is on it — Mackisen ensures fair separation of ownership.
Can CRA collect while I’m disputing my tax balance? Not if Mackisen files a formal objection — collections are suspended by law.
Can CRA cancel penalties and interest after collection? Absolutely — we secure full relief through the Taxpayer Relief Program.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s most experienced defenders against CRA tax collections. Our team of CPAs and tax lawyers act fast to stop garnishments, unfreeze accounts, and negotiate peace with CRA. We act immediately, negotiate intelligently, and defend relentlessly — because your financial life deserves fairness, not fear. When CRA collects aggressively, Mackisen fights decisively.
Call Mackisen CPA Auditors Montreal today for your 2025 Tax Collection Appeal Consultation. The first meeting is free, and your protection starts immediately.