Why a CRA lien is different from an ordinary lien
Most liens come from a creditor who had to sue, win a judgment, and register a writ. CRA doesn’t need a lawsuit or a trial: it certifies the debt with a Federal Court certificate or a provincial judgment, an administrative step, and can then register a lien against your property.CRA And for amounts you collected on the Crown’s behalf — HST/GST and payroll source deductions — CRA can assert a deemed trust that can rank ahead of your existing first mortgage, not behind it, and it doesn’t have to be registered on title at all.CRA
That priority is why lenders treat a CRA claim so seriously and won’t fund into a live one. It also means these files should be treated urgently, especially where payroll or HST/GST is involved. The precise scope of deemed trust and priority is a legal question for your tax lawyer — we coordinate the financing around that advice. This is general information, not legal or tax advice.