Insights

Oct 25, 2025

Mackisen

CRA Wage Garnishment Appeal 2025 — Stop CRA Collections, Release Frozen Accounts, and Protect Your Income

In 2025, CRA’s Wage Garnishment and Collections Program has reached unprecedented levels of enforcement. CRA is now garnishing wages, freezing bank accounts, and intercepting tax refunds automatically through its digital collections system. Many taxpayers first learn of their garnishment only after a portion of their paycheque disappears. CRA does not need a court order to seize wages — but you have the right to fight back. At Mackisen CPA Auditors Montreal, we stop CRA garnishments fast. Our CPA auditors and tax lawyers negotiate directly with CRA Collections, file immediate appeals, and implement structured payment arrangements or taxpayer relief applications to restore financial stability. We don’t let CRA cripple your livelihood — we defend your rights, your income, and your dignity.

Legal and Regulatory Framework

Income Tax Act (Canada)

  • Section 224(1): Authorizes CRA to issue a Requirement to Pay (RTP) to employers, banks, or other parties owing money to a taxpayer.

  • Section 225.1(1): Allows CRA to initiate collections immediately after a tax debt becomes payable.

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

  • Section 165(1): Grants the right to file a Notice of Objection that can suspend collection while a dispute is under review.
    Tax Administration Act (Quebec)
    Revenu Québec enforces similar garnishment and seizure powers at the provincial level. Mackisen coordinates both agencies to stop garnishments across jurisdictions.

Key Court Decisions

Bédard v. The Queen (2022): CRA must act reasonably and proportionally when enforcing wage garnishments.
Thibault v. The Queen (2022): Collections must consider taxpayer hardship before continuing enforcement.
Guindon v. Canada (2015): CRA cannot impose financial punishment beyond what is justified by evidence.
Jordan v. The Queen (2009): Taxpayers have the right to fair process even during active collections.
These precedents confirm that CRA must act with fairness and balance — and Mackisen ensures they do.

Why CRA Garnishes Wages

CRA garnishments are often triggered automatically once a tax balance becomes past due. Common 2025 triggers include:

  • Unpaid income tax, GST/HST, or payroll remittances.

  • Reassessments not appealed within the deadline.

  • Ignored CRA collection letters or missed payment arrangements.

  • Corporate debts linked to director liability.

  • Outstanding tax after audit or objection denial.
    CRA assumes non-compliance — Mackisen proves cooperation and ability to pay.

Mackisen’s Wage Garnishment Defense Strategy

  1. Immediate Action: Contact CRA Collections to freeze further garnishment while representation is established.

  2. Debt Verification: Confirm CRA’s balance accuracy and challenge any unverified reassessment.

  3. Legal Relief Filing: Submit a Taxpayer Relief Application or Notice of Objection to suspend collection activity.

  4. Negotiation and Settlement: Arrange structured payment terms or compromise settlements within your means.

  5. Bank and Employer Coordination: Notify financial institutions and employers to lift or reduce the garnishment order.
    Our proactive strategy stops CRA from draining your income and restores your financial control.

Real Client Experience

A Montreal self-employed professional had 30% of his wages seized by CRA. Mackisen intervened within 24 hours and CRA lifted the garnishment completely.
A Quebec contractor’s corporate account was frozen for $184,000 in back taxes. Mackisen filed an appeal and CRA released the funds and approved a new payment plan.

Common Questions

Can CRA garnish my wages without notice? Yes, but Mackisen can stop it immediately by negotiating or filing an appeal.
Can CRA freeze my business or personal accounts? Yes — Mackisen files urgent relief applications to lift freezes.
Can CRA take my tax refund or benefits? Yes, but we can restructure payments to protect essential income.
Can CRA cancel penalties or interest? Yes — under the Taxpayer Relief Program, Mackisen can eliminate these charges.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s leading defense firm against CRA garnishments and collections. Our integrated team of CPAs and tax lawyers acts immediately to stop seizures, challenge CRA overreach, and rebuild your financial stability. We act fast, argue decisively, and win compassionately — because your paycheque should belong to you, not bureaucracy. When CRA takes your wages, Mackisen takes action.
Call Mackisen CPA Auditors Montreal today for your 2025 Wage Garnishment Defense Consultation. The first meeting is free, and your protection starts immediately.

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