Facing CRA Collections—Garnishments or Bank Freezes?

Stabilize cash flow fast while we build a focused dispute strategy for Toronto & the Greater Toronto Area

If a letter from the Canada Revenue Agency or a sudden requirement to pay has put your business on edge, you need two things: immediate stability and a plan you can understand. This page explains how Misir & Company helps Toronto businesses and individuals stop the scramble, protect legal rights, and resolve CRA disputes methodically—from first contact through Objection → Appeals → Tax Court when required.

Who we help

• Owner-managed corporations & HST registrants dealing with GST/HST reassessments, denied ITCs, or payroll/source-deduction issues.

• Individuals facing reassessments, benefit clawbacks, residency questions, or penalties/interest.

• Accountants & bookkeepers who want legal leadership on escalated files.

• New Canadians who value culturally aware guidance and plain-language steps.

Your immediate 24–72 hour stabilization plan

When you call, we focus on time, cash flow, and control—in that order.

1) Timeline & rights check

• Confirm the 90-day window for filing a Notice of Objection (if an assessment or reassessment has been issued).

• Map other critical dates (statements of account, collection notices, appeal triggers).

• If the clock is tight, file protective paperwork first, then supplement with a complete brief.
  

2) Collections containment

• Review current garnishments, bank holds, liens, or RTPs.

• Identify what’s in dispute versus what can be paid to reduce interest.

• Where appropriate, open dialogue with CRA Collections to stabilize cash flow while the dispute proceeds.
  

3) Evidence triage

• Pull the right books and records (returns, GL, ITC schedules, invoices, receipts, bank and merchant statements).

• Build a document index so every exhibit connects to a number on the notice.

• Flag gaps and assign a practical retrieval plan (supplier corrections, payroll reconciliations, residency proofs).
  

4) Strategy briefing

• Determine whether your file fits Objection, Taxpayer Relief, Voluntary Disclosures Program (VDP), or a hybrid path.

• Give you a one-page plan: what we’ll file, the order we’ll do it in, and what you’ll see next.

What working with our CRA lawyers looks like

Calm, process-driven leadership

| We handle tax controversies daily. You’ll get steady communication, clear next steps, and candid cost/benefit advice at each decision point.

Evidence-first submissions

Objections and negotiations work best when the file is easy to follow. We pair plain-language letters with exhibit-driven evidence (numbered tabs, cross-references, reconciliation schedules) so decision makers can track the logic quickly.

Collaboration with your advisor

Your accountant or bookkeeper is a key partner. They provide accounting detail; we lead the legal submissions, manage Appeals dialogue, and take on Tax Court steps when necessary.

Services you can start today

Objections & Appeals (Income Tax and GST/HST)

• Draft and file Notices of Objection that set out the issues, facts, law/policy, and remedy sought.

• Manage communications with CRA Appeals; answer follow-ups; negotiate variance or vacation of assessments.

• If the decision isn’t favourable, prepare the 90-day court appeal and strategy for Informal or General Procedure.
  

Audit & Post-Assessment Review Responses

• Use our evidence checklist to satisfy information requests efficiently.

• Fix invoice/document defects (e.g., missing GST/HST number, incomplete descriptions).

• Present reconciliations that tie merchant statements → POS → GL → bank so adjustments are clear and targeted.
  

Collections Strategy & Cash-Flow Protection

• Address requirements to pay, garnishments, and bank freezes pragmatically.

• Separate disputed from undisputed amounts; explore payment arrangements or security where appropriate.

• Advise on director liability and steps to limit exposure.
  

Taxpayer Relief (Penalties & Interest)

• Prepare RC4288 applications where extraordinary circumstances or delay justify cancelling penalties/interest.

• Pair relief with the underlying objection or amendment strategy so the file moves as one.
  

Voluntary Disclosures Program (VDP)

• For historic errors or omissions, assess VDP eligibility and assemble a complete, accurate disclosure package.

• Aim to reduce penalties and avoid potential prosecution while resetting compliance.
  

Litigation – Tax Court of Canada

• When negotiation isn’t enough, move efficiently to court with a file that’s already brief-ready.

• Clarify timelines, budget, and probability-weighted outcomes so you decide with confidence.

How we address the four problems most clients bring to us

1) The deadline problem

You may be unsure whether you can still object—or how. We start by confirming dates from the CRA notice and online account records, then protect your rights with timely filings. After that, we focus on the quality of the submission so Appeals has what it needs to vary the result.

2) The collections problem

Collections can feel urgent and personal. We triage what CRA is pursuing, communicate with Collections to stabilize cash flow, and prepare any payment arrangement that makes sense. Meanwhile, we keep building the merits of the file so you’re not just buying time—you’re moving toward a resolution.

3) The documentation problem

Most disputes come down to documents and clarity. We assemble what CRA expects: returns, schedules, invoices/receipts with required details, contracts/SOWs, bank proofs, and reconciliations that match deposits to reported revenue. Where there are gaps, we obtain corrected invoices, supplier attestations, or practical substitutes.

4) The path problem

Not every matter belongs on the same track. We evaluate whether your best route is Objection → Appeals → Court, a Taxpayer Relief request, or VDP. In many files, the right answer is a two-track approach—for example, an objection on the underlying tax plus a relief application for interest.

A quick primer on common CRA actions (and how we respond)

Notices of Assessment / Reassessment

These letters set out CRA’s calculation of your tax. If you disagree, a Notice of Objection is the formal way to challenge it. We analyze the adjustments, explain the 90-day clock, and file a concise, evidence-backed objection.

GST/HST Reviews and Reassessments

ITC denials and coding issues are common. Our checklists tighten invoice standards, reconcile revenue, and present place-of-supply logic persuasively. We also plan around the reality that collections may continue on GST/HST while you dispute.

Audit Requests for Information (RFIs)

We respond with organized packages—no data dumps. Each exhibit is labeled; each label ties to a number on CRA’s query, reducing confusion and follow-ups.

Requirements to Pay / Garnishments

We engage Collections with a realistic plan: what can be paid now, what is being disputed, and how we’re moving the file forward. When appropriate, we seek arrangements that keep payroll and operations stable.

The evidence checklist (useful for both audits and objections)

• Assessment or reassessment notice and any CRA correspondence.

• Tax returns and relevant schedules for the periods in question.

• General ledger & trial balance extracts; ITC schedules for GST/HST.

• Sales documentation: invoices, POS/e-commerce reports, merchant statements, and bank deposit listings.

• Purchase documentation: invoices/receipts showing supplier legal name, GST/HST registration, invoice number/date, clear descriptions, and tax charged.

• Contracts/SOWs to explain the nature of supplies and place-of-supply logic.

• Payment proof: bank/credit statements, EFT confirmations, or cleared cheques.

• Context memos: short notes linking exhibits to CRA’s adjustments.

• Corrections: revised invoices or supplier letters addressing document defects.
  

We’ll adapt this list to your industry (construction, professional services, retail, logistics, hospitality, e-commerce, and more).

Real-world scenarios we resolve in Toronto & the GTA

• ITCs denied because supplier invoices lacked registration numbers or adequate descriptions—cured with corrected invoices, payment proofs, and usage evidence.

• Unreported sales flagged by merchant or bank deposits—resolved through reconciliations that track deposits, chargebacks, fees, and timing differences.

• Payroll/source-deduction balances after a records review—addressed with corrections and, where appropriate, Taxpayer Relief for penalties.

• Residency and benefit issues for newcomers—clarified with travel logs, tenancy records, and employment agreements.

• Late-filed returns creating penalty/interest spikes—paired Relief requests and realistic payment plans.

What to expect when you work with us

Clear deliverables

• A timeline map and protective filings as needed

• A position letter in plain language

• An exhibit index that decision makers can navigate

• Regular status updates and target milestones

• A closing memo outlining results and next steps

Communication style

Professional, respectful, and calm under pressure. We make complex processes feel manageable and avoid surprises.

FAQs

Do I need a lawyer if my accountant is already helping?

Many files benefit from both. Your accountant provides the numbers; our CRA lawyers handle legal arguments, objections/appeals, and court processes. We coordinate so work isn’t duplicated.

Will CRA pause collections during my dispute?

Not always. For GST/HST, collections may continue even while you object. We address collections early with a cash-flow plan and, where suitable, payment arrangements.

How long does an objection take?

Timelines vary by complexity and inventory. We set expectations up front and keep you informed as the file moves through Appeals.

What if I missed the 90-day objection window?

There may be extension options. Contact us quickly—we’ll evaluate eligibility and, if appropriate, file both the objection and extension request with supporting reasons.

Can you help if I want to clean up past issues?

Yes. We assess Voluntary Disclosures Program eligibility and prepare the package to correct historical errors while minimizing penalties.

Your action plan (Toronto & the GTA)

If you have an assessment/reassessment and time is short

1. Send us the notice, any working papers, and your timeline (when you received it).

2. We confirm dates and file a Notice of Objection where warranted.

3. We assemble an evidence-backed submission and keep you updated on Appeals progress.
   

If you’re facing collections pressure

1. Share the latest statements of account and any RTPs/garnishment letters.

2. We separate disputed vs. undisputed amounts and engage Collections to stabilize cash flow.

3. In parallel, we push the dispute forward so you’re moving toward resolution, not just holding the line.

Why Toronto chooses Misir & Company for CRA disputes

• Focused on tax controversy. Objections, audits, collections strategy, and Tax Court are a core part of our practice.

• Evidence-first approach. We translate your situation into decision-ready packages that are easy to follow.

• Accessible and local. Based at 880 St Clair Ave West, Toronto, we serve the GTA in person or virtually.

• Future-proofing. After the dust settles, we leave you with practical controls (invoice standards, reconciliation checklists) to reduce repeat risk.

About Misir & Company Lawyers

Address: 880 St Clair Ave West, Toronto, ON, Canada Phone: 416-865-6274 Website: misirandcompany.ca

We guide clients across Toronto & the Greater Toronto Area through CRA audits, reassessments, objections, collections, Taxpayer Relief, VDP, and Tax Court with clear steps and steady communication.

Ready to regain control?

Start with a short call. Tell us what CRA sent and when you received it. We’ll confirm deadlines, steady cash flow, and map your best path—Objection, Relief, VDP, or Court.

Call 416-865-6274 or send your documents securely to begin.