CRA Director Liability Audit — Montreal CPA Firm Near You: Shield Your Personal Assets

A CRA Director Liability Audit targets corporate directors personally for unremitted payroll source deductions, GST/HST, or QST. When a company fails to remit trust funds, CRA and Revenue Québec can legally hold directors jointly and severally liable for those debts. Mackisen CPA Montreal provides expert defense to protect directors’ personal assets, demonstrating due diligence, financial hardship, and proper corporate governance procedures.

Legal Foundation

Law: Income Tax Act s.227.1; Excise Tax Act s.323; Tax Administration Act (Québec) ss.40–44.
Jurisprudence: Soper v. Canada (1997 FCA) — established that directors can avoid liability if they prove reasonable steps were taken to prevent non-compliance, even when the company became insolvent.

Why You Need a CPA for a Director Liability Audit

CRA’s Director Liability Program aggressively enforces payroll and GST/QST arrears. Once assessed, directors may face wage garnishments, liens, or personal bank account seizures. A CPA ensures your financial controls and evidence of due diligence protect you from personal exposure.

Mackisen CPA Montreal reconstructs payment history, remittance evidence, and correspondence with CRA and ARQ to prove the director acted responsibly and without negligence.

Learning insight: CRA doesn’t need intent—it only needs omission. A CPA proves you acted with care, not neglect.

What Mackisen CPA’s Director Liability Defense Includes

• Complete review of remittance schedules, PD7A forms, and CRA/ARQ account statements.

• Analysis of director appointment dates and statutory limitation periods (2-year rule after resignation).

• Documentation of efforts to secure financing, prioritize remittances, or engage CRA payment plans.

• Legal collaboration for objections, appeals, and Tax Court filings if assessments are unjust.

• Negotiation of payment or compromise arrangements to prevent personal enforcement.

Learning insight: Director liability is not about what failed—it’s about what you tried. A CPA shows the effort that proves diligence.

Common Triggers for CRA Director Liability Audits

• Company bankruptcy or dissolution without full payment of trust taxes.

• CRA collections linking directors to unremitted payroll or GST/HST accounts.

• Resignation filings without clear proof of departure date or role.

• Missing or unsigned remittance forms and reconciliations.

• Evidence of director control over financial decisions during arrears period.

Mackisen CPA Montreal identifies these exposure points early and builds a full defense record to stop assessments before they become personal.

How Mackisen CPA Manages Director Liability Audits

1. Verifies the timeline of directorship and resignation filings to determine legal exposure.

2. Compiles all correspondence, payment records, and CRA filings proving efforts to comply.

3. Drafts a Director Due Diligence Report documenting financial decisions and mitigation attempts.

4. Negotiates payment arrangements or fairness-relief applications to prevent enforcement.

5. Collaborates with legal counsel if a Notice of Assessment is already issued.

Learning insight: CRA pursues directors personally only when the company’s story is missing. A CPA fills in that story with facts and proof.

Benefits of Professional Representation

• Prevents personal liability for corporate payroll and GST/QST debts.

• Stops garnishment or bank seizures through due diligence filings.

• Reduces penalties via fairness and hardship relief programs.

• Demonstrates accountability to regulators and creditors.

• Protects directors’ personal credit and reputation.

Learning insight: Directors can’t delegate responsibility—but they can prove diligence. A CPA helps turn that proof into protection.

SEO Optimization and Learning Value

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Learning insight: CRA collects from people who can pay, not from those who should. Mackisen CPA ensures you’re removed from that list.

Real Client Success

• A Montreal director avoided a $180,000 payroll liability after Mackisen CPA proved his resignation was effective two years before the debt period.

• A manufacturer’s director cleared a $92,000 GST assessment by showing timely but misapplied payments.

• A restaurant group’s directors jointly avoided penalty when our firm produced board minutes showing active efforts to secure financing.

Why Mackisen CPA Montreal

Mackisen CPA Montreal combines audit defense with corporate-governance expertise. Our CPA team has successfully represented directors in federal and provincial due-diligence appeals, protecting personal assets and professional reputations.

Learning insight: CRA enforces liability through assumption. Mackisen CPA replaces assumption with documentation—and documentation wins.

Learning conclusion: A director’s best defense is diligence documented. Mackisen CPA Montreal transforms diligence into immunity—protecting what you built from what you didn’t control.