Negotiating A CRA Payment Plan 2025

If you owe money to the Canada Revenue Agency (CRA) or Revenu Québec, the worst thing you can do is ignore it. In 2025, CRA’s collection technology is fully automated—within days of a missed payment, your file can move to enforcement, wage garnishment, or a Requirement to Pay. But here’s the good news: CRA is often willing to negotiate—if you know how to approach them correctly.

A CRA payment plan allows you to pay your balance over time, but it must be carefully structured to prevent default or reassessment. Without a strong financial presentation, CRA may demand unrealistic payments or reject your proposal entirely. At Mackisen CPA Auditors Montreal, we negotiate directly with CRA and Revenu Québec to secure manageable, compliant, and sustainable payment arrangements—protecting your income, assets, and business.

We don’t just negotiate—we build your defense, present your case with authority, and ensure you never face collections or enforcement again.

Legal and Regulatory Framework

Income Tax Act (Canada)
Section 161(1): Applies daily compounding interest on unpaid tax balances.
Section 222: Authorizes CRA to initiate legal recovery actions for unpaid tax debts.
Section 220(3.1): Provides for penalty and interest cancellation under the Taxpayer Relief Program when financial hardship exists.
CRA Collections Policy Manual: Allows payment arrangements when taxpayers cannot pay in full but demonstrate consistent payment ability.

Tax Administration Act (Quebec)
Revenu Québec offers payment agreements for provincial balances under financial hardship, provided you maintain future compliance.

Mackisen prepares all documentation, cash flow analyses, and formal submissions required to support your negotiation and ensure your plan is approved on the first attempt.

Key Court Decisions

Jordan v. The Queen (2009): Interest continues to accrue until balances are fully paid or relieved through formal approval.
Venne v. The Queen (1984): Taxpayers are obligated to demonstrate cooperation and transparency when negotiating with CRA.
Guindon v. Canada (2015): CRA penalties remain enforceable unless addressed through approved relief or settlement.

These decisions confirm one critical truth: negotiation must be proactive, strategic, and well-documented.

Why Negotiating a CRA Payment Plan Matters

A properly structured CRA payment plan protects you from enforcement and buys you time to stabilize your finances. Once approved, the CRA halts garnishments, bank freezes, and collection calls—as long as you remain compliant.

Key Benefits of a CRA Payment Plan:

• Stops immediate collection actions and garnishments.

• Prevents property liens or account seizures.

• Protects your credit and professional reputation.

• Provides breathing room to manage cash flow.

• Allows penalty and interest reduction applications once compliance is restored.

Common CRA Mistakes in 2025:

• Proposing payments too low without justification.

• Failing to file required returns before negotiation.

• Ignoring CRA correspondence or missing deadlines.

• Submitting incomplete financial documentation.

• Negotiating without professional support—leading to denial or default.

Mackisen’s Payment Plan Negotiation and Protection Strategy

1. Debt Analysis: Review CRA and Revenu Québec balances, penalties, and interest.

2. Financial Assessment: Prepare detailed income, expense, and asset documentation to support a fair proposal.

3. Direct Negotiation: Communicate with CRA officers to stop enforcement and present your plan.

4. Legal Safeguards: Secure written confirmation of the agreement to prevent future reassessment or collection.

5. Long-Term Compliance: Establish automated systems to keep filings and payments current.

Our method turns chaos into structure—ensuring the CRA sees you as a cooperative taxpayer, not a delinquent one.

Real Client Experience

A Montreal retailer owed $125,000 in payroll and GST arrears. CRA threatened wage garnishment. Mackisen presented financial hardship evidence and negotiated a 36-month plan with no enforcement actions.
A self-employed consultant owed $42,000 in back taxes. CRA initially demanded $1,800/month. Mackisen’s recalculated proposal based on accurate financials reduced the payment to $680/month—approved within 10 days.

Common Questions

Can CRA refuse a payment plan? Yes, if they believe you can pay more or fail to provide documentation. Mackisen ensures your proposal is realistic and persuasive.
Will interest stop during the plan? No, interest continues until the balance is paid—but we can request reduction through the Taxpayer Relief Program.
What happens if I miss a payment? CRA can cancel the plan and resume collections immediately. Mackisen helps you avoid default.
Can I include both CRA and Revenu Québec debts? Yes, we coordinate both agencies for one unified repayment strategy.

Why Mackisen

At Mackisen CPA Auditors Montreal, we understand how stressful tax debt can be—and how quickly CRA pressure can escalate. Our experts act fast to secure agreements that protect your finances, your assets, and your dignity. We speak CRA’s language and know exactly how to negotiate successfully.

We combine professionalism, strategy, and empathy to help you move from crisis to control. With Mackisen, you’ll have not just a payment plan—but a financial recovery plan.

Call Mackisen CPA Auditors Montreal today for your 2025 CRA Payment Plan Consultation. The first meeting is free, and your protection begins immediately.