Insights

Oct 25, 2025

Mackisen

CRA Tax Collection Defense 2025 — Stop CRA Garnishments, Protect Your Assets, and Regain Financial Control with Mackisen

CRA’s Collection Enforcement Program has become one of the most powerful and automated debt recovery systems in Canada. CRA can now freeze bank accounts, garnish wages, and seize assets without court approval. Many Canadians are facing aggressive collection actions based on disputed balances or delayed filings, and most don’t realize they have the right to stop CRA’s actions immediately through legal representation. At Mackisen CPA Auditors Montreal, we protect taxpayers from CRA’s most severe collection tactics. Our CPA auditors and tax lawyers intervene immediately to halt garnishments, negotiate settlements, and eliminate penalties through the Taxpayer Relief Program. We don’t let CRA destroy your financial stability — we fight for your right to fairness, protection, and peace of mind.

Legal and Regulatory Framework

Income Tax Act (Canada) Section 224(1): Grants CRA the authority to issue a Requirement to Pay (RTP) to garnish wages or freeze bank accounts, which Mackisen stops through appeal and negotiation. Section 225.1(1): Suspends CRA’s collection powers when a formal objection or appeal is filed. Section 220(3.1): Enables CRA to cancel or reduce penalties and interest under the Taxpayer Relief Program. Section 165(1): Allows taxpayers to file a Notice of Objection to dispute assessments and trigger collection suspension. Section 222(1): Governs CRA’s authority to enforce payment but requires fair administrative conduct.
Tax Administration Act (Quebec) Revenu Québec enforces similar powers for provincial tax debts, including bank seizures and wage garnishments. Mackisen coordinates both levels to stop all enforcement actions and protect your finances.

Key Court Decisions

Bédard v. The Queen (2022): CRA must exercise fairness and reasonableness in enforcing collections. Thibault v. The Queen (2022): Taxpayers under active dispute cannot be subject to garnishment. Guindon v. Canada (2015): Good faith and reasonable conduct are valid grounds for penalty cancellation. Jordan v. The Queen (2009): CRA must respect taxpayer rights to due process before taking collection action. These cases confirm that CRA’s power to collect is not unlimited — and can be challenged effectively.

Why CRA Enforces Collections

CRA’s 2025 collection systems automatically flag overdue accounts after reassessments, missed installment payments, or unfiled returns. Common triggers include unresolved audits, payroll arrears, GST/HST debt, or unpaid reassessments. CRA assumes non-payment means avoidance — Mackisen proves cooperation, documentation, and financial capacity.

Mackisen’s Tax Collection Defense Strategy

  1. Immediate Intervention: Contact CRA Collections directly to suspend active enforcement actions. 2. Debt Verification: Review CRA’s records and confirm the legitimacy and calculation of the debt. 3. Objection and Appeal Filing: Submit a Notice of Objection under Section 165(1) to freeze collection activity. 4. Negotiation and Settlement: Establish affordable payment terms or negotiate partial forgiveness under fairness provisions. 5. Penalty and Interest Relief: File under Section 220(3.1) to cancel or reduce financial charges due to hardship or administrative error. Mackisen’s approach neutralizes CRA’s aggression and replaces chaos with control.

Real Client Experience

A Montreal business owner had their bank account frozen for $176,000 in tax arrears. Mackisen intervened immediately, released the funds, and negotiated a payment plan within 48 hours. A Quebec freelancer faced wage garnishment for a disputed tax balance. Mackisen filed an objection, suspended enforcement, and CRA later withdrew the debt entirely.

Common Questions

Can CRA freeze my account without warning? Yes, but Mackisen can reverse or lift the freeze quickly through proper representation. Can CRA collect while I appeal my tax bill? No, collections are suspended once an objection is filed. Can CRA seize personal assets for business debt? Only if ownership is proven — Mackisen separates personal and corporate liability. Can penalties and interest be cancelled? Absolutely, through a Taxpayer Relief Application.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s trusted authority in CRA tax collection defense. Our team of CPAs and tax lawyers acts fast to stop garnishments, negotiate relief, and protect your financial well-being. We move strategically, argue intelligently, and fight relentlessly — because financial protection is not optional, it’s your right. When CRA collects aggressively, Mackisen responds decisively. Call Mackisen CPA Auditors Montreal today for your 2025 Tax Collection Defense Consultation. The first meeting is free, and your protection starts immediately.

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