CRA will consider forms of security other than an LC for assessed taxes and interest

ETA s. 314(2) provides that “the Minister shall accept security, in an amount and a form satisfactory to the Minister … for payment of any amount that [has been objected to].” (ITA s. 220(4.1) more laconically refers to “adequate security.”) After referring to the “Bank Letter of Guarantee or Irrevocable Standby Letter of Credit” as THE acceptable security, CRA acknowledged:

However, if a form of security is being proposed, the Minister will review the proposed security during the course of administering the ETA, and determine whether it is advisable to accept the proposed security.

Neal Armstrong. Summary of 28 February 2019 CBA Roundtable, Q.10 under ETA s. 314(2).