Insight

Nov 24, 2025

Mackisen

CRA GST/HST Compliance Audit — Montreal CPA Firm Near You: ITCs and Place-of-Supply Defense

A CRA GST/HST Compliance Audit reviews whether your business properly collects, remits, and claims Goods and Services Tax (GST) or Harmonized Sales Tax (HST). The focus is on documentation — specifically, whether every Input Tax Credit (ITC) and place-of-supply rule was applied correctly.
Mackisen CPA Montreal provides professional audit defense, supplier verification, and rate validation, ensuring your GST/HST returns meet every CRA standard while minimizing exposure to penalties or refund delays.


Legal Foundation

Law: Excise Tax Act (ETA) ss.165–169 (imposition and entitlement), s.286 (record-keeping), s.289 (CRA’s audit powers).
Jurisprudence: Northwest Company Inc. v. Canada (2011 TCC) — ITCs are disallowed if invoices lack complete information, even when GST/HST has been paid.

Learning insight: CRA doesn’t dispute your right to claim — it disputes your proof. Mackisen CPA ensures your invoices, payments, and rates are beyond question.


Why CRA Conducts GST/HST Audits

CRA’s automated systems flag anomalies in filings, refund claims, or supplier data. Common triggers include:

  • Large or recurring refund claims relative to sales.

  • Missing or invalid supplier registration numbers.

  • Incorrect application of place-of-supply rules between provinces.

  • Mismatched GST/HST filings and income tax returns.

  • Claims for personal or mixed-use expenses.

Learning insight: CRA audits imbalances — not intentions. Mackisen CPA ensures your documentation explains every variance before CRA asks.


CRA’s GST/HST Audit Process

  1. Audit Notice: CRA issues a letter identifying the periods under review.

  2. Document Request: CRA demands invoices, contracts, and proof of payment for claimed ITCs.

  3. Rate Verification: CRA tests if proper provincial HST rates were applied.

  4. Place-of-Supply Review: CRA checks whether the correct jurisdiction received tax.

  5. Audit Result: CRA may issue an adjustment, refund denial, or clearance letter.

Learning insight: CRA’s process is about matching data points. Mackisen CPA connects those dots before CRA does.


Mackisen CPA’s GST/HST Audit Defense Framework

  1. Invoice Validation: Confirm all mandatory elements under ETA s.169(4) (name, GST number, date, tax amount).

  2. Supplier Verification: Cross-check registration with CRA’s online database.

  3. Rate Reconciliation: Confirm correct place-of-supply rates (5%, 13%, or 15%).

  4. Payment Proof: Link each ITC to an actual transaction in your ledger or bank records.

  5. CRA Representation: Manage all communication and evidence submission directly with auditors.

Learning insight: CRA audits paperwork — Mackisen CPA audits the story behind it. We make sure your paperwork tells that story clearly.


Common Issues CRA Finds in GST/HST Audits

  • ITCs claimed from unregistered suppliers.

  • Invoices missing legal names, tax breakdowns, or registration numbers.

  • Incorrect HST rate due to cross-border or interprovincial sales.

  • Overclaimed ITCs on mixed-use or personal items.

  • Zero-rating applied without export or qualifying documentation.

Mackisen CPA corrects or supplements documentation to meet CRA’s verification standards, ensuring legitimate credits are approved.

Learning insight: CRA denies ITCs on technicalities, not truth. Mackisen CPA bridges that gap.


Place-of-Supply Rules: A Frequent Audit Focus

CRA determines GST/HST rate based on where goods or services are consumed — not where they are billed.

  • Québec & Alberta: 5% GST only.

  • Ontario: 13% HST.

  • Atlantic Provinces: 15% HST (Nova Scotia, PEI, Newfoundland & Labrador, New Brunswick).
    Mackisen CPA ensures every transaction applies the correct tax rate for the proper jurisdiction, preventing reassessments or refund denials.

Learning insight: Geography determines liability — precision determines compliance.


Real-World Case Studies

  • A Montréal manufacturer recovered $210,000 in denied ITCs after Mackisen CPA proved supplier registration and corrected missing tax data.

  • A logistics firm cleared a $75,000 reassessment when we provided shipping and export documents supporting zero-rated sales.

  • A professional firm’s refund was released in 10 days after we submitted CPA-certified ITC reconciliation tables.

Learning insight: CRA closes files faster when your evidence looks professional. Mackisen CPA ensures every document meets audit standards.


SEO Optimization and Educational Value

Primary Keywords: CRA GST/HST Audit, GST/HST Compliance Canada, Mackisen CPA Montreal, CPA Firm Near You, Input Tax Credit Verification, Place-of-Supply Rules.
Secondary Keywords: CRA GST refund audit, HST ITC documentation, CRA tax rate verification, Mackisen CPA audit defense, Revenu Québec QST review.

Learning insight: SEO and audit compliance share one foundation — clarity. Mackisen CPA produces content and compliance that both rank high.


Why Mackisen CPA Montreal

With over 35 years of expertise in indirect taxation and audit defense, Mackisen CPA Montreal represents corporations, professionals, and SMEs through every stage of CRA or ARQ GST/HST verification.
Our bilingual team combines tax-law knowledge, forensic accounting, and negotiation skills to protect your credits, minimize penalties, and accelerate refund release.

Learning insight: CRA measures compliance in documentation — Mackisen CPA turns documentation into a defense system.


Call to Action

If CRA or Revenu Québec has contacted your business about GST/HST compliance, refund holds, or rate verification, contact Mackisen CPA Montreal immediately.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com

Learning conclusion: CRA GST/HST audits test documentation, not honesty. Mackisen CPA Montreal ensures every invoice, rate, and record withstands CRA scrutiny — protecting your business, your credits, and your peace of mind.

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