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Illustrative exampleCRA debt Ottawa, ON· Refinance · CRA lien · Private

Example: clearing a registered CRA lien with a private second mortgage

Illustrative example, not a real client file. A composite scenario showing how a file like this can be structured. Any rate shown is a dated assumption, not a current rate or offer; see today’s rates on our live board.

An illustrative homeowner whose income-tax and HST arrears have escalated to a registered CRA lien is declined by banks; a private second mortgage pays CRA, and the lien is discharged from title.

Borrower (illustrative)
Homeowner, incorporated, income-tax + HST arrears escalated to a registered CRA lien
Situation
Strong home equity, but every A-lender declined because of the lien on title
Goal
Clear the CRA lien, stop enforcement, and restore clean title
The challenge

Once CRA registered a lien, the file fell outside A-lender guidelines: banks generally won't lend while a CRA lien sits on title, and for the HST portion CRA's deemed-trust rights can rank ahead of other creditors.

Interest kept compounding daily while the balance sat, and the borrower had been told, incorrectly, that a lien meant the home was simply at risk with no financing option.

What we did

We confirmed the title position with a parcel register and sized a private second mortgage to cover the full CRA payout plus costs, leaving a healthy equity cushion. Because equity was strong, the combined loan-to-value stayed conservative.

At funding, the money flowed from the lawyer's trust account directly to CRA. Once the balance was confirmed paid, CRA released the lien, the discharge was registered, and the private lender's charge sat against clean title.

We set the exit from day one: stay current on filings and remittances, season the file, and refinance back to A-lender pricing once it stabilizes.

The outcome
Home value
$850,000
First mortgage
$470,000
CRA payout
~$78,000
Private second (incl. fees)
~$95,000 (~66% combined LTV)
Result
Balance paid · lien discharged
Exit plan
Refinance to A as file stabilizes

The registered CRA lien came off title and enforcement stopped. The private premium is a real, temporary cost — far cheaper than a CRA balance compounding under an enforceable lien — and the plan is to refinance to A-lender pricing once the tax history stabilizes.

Figures are illustrative scenario assumptions (2026), not current rates, quotes or a record of a funded deal. For current pricing, see today’s rates.

The takeaway

A registered CRA lien blocks banks, but it doesn't block financing outright. With equity, a private (or B-lender) refinance clears the lien at closing and restores clean title — then you refinance back to prime once the file heals.

Rules and sources this example relies on

  1. Putting a lien on or seizing your assets (Canada Revenue Agency)
  2. Excise Tax Act, s. 222 (GST/HST deemed trust) (Justice Laws (Government of Canada))
  3. Income Tax Act, s. 227 (withholding / source-deduction deemed trust) (Justice Laws (Government of Canada))
  4. Borrowing against home equity (Financial Consumer Agency of Canada)

Illustrative example, not a real client file. This scenario is a composite written to show how a file like this can be structured; it describes no real client, and no real outcome is claimed. Any rate shown is a dated scenario assumption (2026), not a current rate or offer. Approvals, rates, fees and costs depend on your situation and on lender and insurer criteria at the time of application.

In a similar situation?

Every file is different — but the playbook is the same: the right lender, structured properly. Tell us your situation and we'll map your options. Free, no credit pull to start.

FAQ

Common questions

Can I get a mortgage if CRA has registered a lien on my property?
Not from a bank, but a B-lender or private lender can refinance against your equity to pay CRA out and clear the lien at closing, restoring clean title. It costs more than an A-lender and is meant to be temporary, with a plan to refinance to prime once your file stabilizes. It depends mainly on your equity.
What is a CRA deemed trust?
For amounts collected for the Crown — HST/GST and payroll source deductions — CRA can assert a deemed trust that can rank ahead of your existing mortgage. That priority is what makes CRA claims uniquely serious for a homeowner. The precise legal scope is a matter for your tax lawyer.
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