CRA Large-Case GST/HST Audit — Montreal CPA Firm Near You: Complex Transactions

A CRA Large-Case GST/HST Audit is an intensive, high-stakes verification designed for corporations with multi-jurisdictional, intercompany, or high-value transactions. These audits are led by CRA’s Large Business Audit Division and target businesses whose GST/HST filings involve complex supply chains, interprovincial sales, or significant refund claims.
Mackisen CPA Montreal provides expert representation, reconciliation, and documentation for large corporations — ensuring every GST/HST credit, rate, and transaction is supported and defensible under the Excise Tax Act.

Legal Foundation

Law: Excise Tax Act ss.165–169 (tax on supplies and ITC entitlement), s.286 (record-keeping), s.288 (audit and inspection powers).
Jurisprudence: GlaxoSmithKline Inc. v. Canada (2012 SCC) — confirmed that tax authorities must consider commercial reality and business purpose, not just form, when assessing transactions.

Learning insight: CRA large-case auditors don’t look for small errors — they look for systems. Mackisen CPA ensures your system proves control, compliance, and credibility.

Why CRA Targets Large-Case Audits

CRA selects large-case audits based on financial magnitude, complexity, and intercompany relationships. These audits commonly involve:

• Related-party transactions and transfer pricing adjustments.

• Interprovincial and cross-border supply of goods and services.

• Large Input Tax Credit (ITC) claims and refund patterns.

• Mergers, acquisitions, or reorganizations.

• Industry-specific risks (construction, manufacturing, finance, logistics).

Learning insight: The larger your operation, the greater the expectation of documentation. Mackisen CPA meets that expectation before CRA asks.

How CRA Conducts a Large-Case GST/HST Audit

1. Audit Launch: CRA sends a large-business audit notice and assigns a dedicated team.

2. Data Review: CRA analyzes returns, intercompany ledgers, and refund patterns.

3. Transaction Testing: High-value invoices, contracts, and ITCs are verified individually.

4. Intercompany Coordination: CRA compares group-company records to detect mismatches.

5. Proposal Letter: CRA issues adjustments or refund denials with supporting rationale.

6. Resolution: Mackisen CPA responds with evidence, citations, and technical explanations before reassessment.

Learning insight: CRA’s process is forensic — not conversational. Mackisen CPA makes sure your documents do the talking.

Mackisen CPA’s Large-Case Audit Defense Framework

1. Audit Readiness Review: Assess systems, processes, and internal controls for CRA compliance.

2. ITC Documentation Verification: Validate supplier invoices, payment proof, and tax registration.

3. Cross-Entity Reconciliation: Align GST/HST collected and claimed across subsidiaries.

4. Place-of-Supply Proof: Confirm correct rate applications across provinces and exports.

5. CRA Liaison: Manage all communications, from audit planning to closing reports.

6. Post-Audit Compliance: Implement process improvements to prevent recurrence.

Learning insight: CRA challenges systems that are inconsistent — not transparent ones. Mackisen CPA builds consistency into every ledger and filing.

Key CRA Focus Areas in Large-Case Audits

• Intercompany Invoices: Proper tax registration and commercial rationale for related-party charges.

• Mixed-Use Assets: Allocation of ITCs between taxable and exempt operations.

• Cross-Border Supplies: Proof of zero-rating under Schedule VI of the ETA.

• ITC Refunds: Verification of timing, eligibility, and proper claim documentation.

• Digital or Intangible Services: Application of place-of-supply rules for non-tangible transactions.

Learning insight: CRA assumes complexity increases risk. Mackisen CPA turns complexity into documented compliance.

Real-World Case Studies

• A Montréal manufacturer avoided a $950,000 reassessment when Mackisen CPA proved intercompany transfers were zero-rated under ETA Schedule VI.

• A technology distributor secured the release of $1.4M in refunds by validating digital supply-place rules across multiple provinces.

• A logistics group reduced CRA adjustments by 92% after our team provided detailed ITC allocation reconciliations across four subsidiaries.

Learning insight: CRA respects clarity — Mackisen CPA ensures your records are beyond question.

SEO Optimization and Learning Value

Primary Keywords: CRA Large-Case Audit, Mackisen CPA Montreal, CPA Firm Near You, GST/HST Corporate Audit, CRA Large Business Audit, CRA ITC Documentation.
Secondary Keywords: CRA intercompany audit, CRA GST refund defense, large corporate compliance Québec, CRA place-of-supply verification, Mackisen CPA Montreal business audit.

Learning insight: CRA audits precision — Google ranks precision. Mackisen CPA masters both.

Why Mackisen CPA Montreal

Mackisen CPA Montreal has over 35 years of combined experience managing large corporate audits for clients across Québec and Canada. Our bilingual CPAs, auditors, and tax specialists align accounting, legal, and operational systems to withstand CRA and Revenu Québec reviews.
We don’t just defend your file — we strengthen your infrastructure for future compliance and faster refunds.

Learning insight: Large-case audits test your systems, not your integrity. Mackisen CPA ensures both emerge stronger.

Call to Action

If CRA has selected your corporation for a Large-Case GST/HST Audit or you’ve received an audit proposal letter, act immediately.
Contact Mackisen CPA Montreal for professional representation, intercompany reconciliation, and corporate audit management.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com

Learning conclusion: A CRA Large-Case Audit is not a setback — it’s an examination of your systems. Mackisen CPA Montreal ensures your systems pass every test — turning scrutiny into stability and compliance into confidence.