CRA GST/HST Contractor for Disability Support, Autism Therapy (Non-Regulated) & ABA Home Programs Audit — Montreal CPA Firm Near You: Defending Taxable vs Exempt Services, Travel Fees, Subcontractors & ITCs

This is one of CRA’s most sensitive and heavily audited sectors because families and service providers often assume disability-related or autism-support services are “healthcare exempt.” In reality:

✔ Only regulated health professionals providing medical treatment can be exempt.
✘ Behavioural therapists, ABA tutors, shadow teachers, respite aides, autism program workers and home-support educators are not regulated under healthcare law, meaning their services are fully taxable unless operating under a regulated clinic.

Mackisen CPA Montreal specializes in defending ABA tutors, autism-support contractors, learning-support aides, respite helpers and developmental-support workers in CRA audits by classifying services correctly, validating subcontractor GST compliance, and reconstructing ITCs.

Legal Foundation

Excise Tax Act – Exemption Rules

Exempt services (Schedule V, Part II):
Provided only by regulated health professionals (e.g., psychologists, occupational therapists, speech-language pathologists).

NOT exempt (always taxable):

• ABA (Applied Behaviour Analysis)

• IBI (Intensive Behavioural Intervention)

• ESDM / early-intervention programs

• Behaviour technician services

• Autism respite support

• In-class shadow support

• Life-skills coaching

• Special-needs tutoring

• Developmental support sessions

• Home-based behaviour programs

Other Relevant ETA Sections

• s.165 — GST/HST applies unless legally exempt

• s.221 — contractor must collect tax

• s.169 — ITCs require full documentation

• s.141.01 — mixed-use equipment/vehicle allocation

• Schedule IX — place-of-supply based on location of child/family receiving service

• s.123(1) — “practitioner,” “healthcare service,” “consideration”

Case Law & CRA Positions

• ABA is not an exempt health service

• Behaviour therapy is taxable unless delivered by regulated psychologists

• Respite support = taxable

• Shadow teaching = taxable

• Royal Bank v. Canada: ITCs invalid without proper documentation

Learning insight: ABA and developmental support are educational/behavioural, not medical — therefore fully taxable.

Why CRA Audits ABA Tutors, Autism-Support Workers & Developmental Support Providers

Revenue Risks

• GST/HST not charged on ABA/IBI services
• sessions wrongly described as “healthcare”
• home-visit fees charged without tax
• cash/e-transfer payments unreported
• program packages (weekly blocks) not invoiced
• in-school support coded incorrectly
• respite hours treated as exempt
• deposits for long-term programs omitted
• multi-location sessions misrated (QC/ON/Atlantic)

Subcontractor Risks

• ABA tutors without GST registration
• shadow teachers paid cash
• helpers misclassified (contractor vs employee)
• missing subcontractor invoices
• unverified GST numbers

ITC Risks

• missing receipts for:
– toys, teaching tools
– reinforcement materials
– sensory equipment
– apps, online learning tools
– PPE & travel costs
– mileage & communication tools
• imported therapy items without self-assessment (s.218)
• personal-use equipment claimed
• home-office expenses overclaimed

Operational Risks

• session logs missing
• program notes not matching billed hours
• inconsistent invoicing patterns
• communication logs (WhatsApp/SMS) not reconciled
• school-visit hours not recorded
• misinterpretation of “medically necessary services”

High-risk operators:

• independent ABA tutors

• special-needs support contractors

• autism-program technicians

• classroom shadow aides

• respite and behavioural support workers

Learning insight: CRA’s main focus is incorrect exemption claims + subcontractor compliance + unreported e-transfers.

CRA ABA/Developmental Support Audit Process

1. CRA requests:
   – invoices (sessions, program blocks, travel)
   – session logs & behaviour notes
   – subcontractor invoices + GST numbers
   – bank & e-transfer statements
   – mileage logs
   – receipts for tools, toys, sensory items
   – software subscriptions
   – ITC spreadsheets
   – caregiver/program agreements
   – import receipts

2. CRA tests:
   • is the service exempt (regulated) or taxable (non-regulated)?
   • GST/HST applied correctly?
   • subcontractor GST registration valid?
   • ITC documentation complete?
   • logs → invoices → deposits alignment
   • travel/visit fees taxed?
   • imported tools self-assessed?
   • mixed provincial sessions rated correctly?

3. CRA issues a Proposed Audit Adjustment.

4. Mackisen CPA prepares full legal + documentary defense.

Learning insight: CRA rebuilds the year from session logs, WhatsApp scheduling, deposits & parental payments.

Mackisen CPA’s ABA & Support-Worker Audit Defense Strategy

• create a Tax Matrix: ABA, respite, shadow support, parent-training, travel
• rebuild compliant GST/HST invoices
• validate subcontractor GST numbers
• reconstruct ITC binder (toys, sensory tools, mileage, equipment)
• correct place-of-supply for multi-region support
• reconcile logs → invoices → deposits → GST returns
• defend mileage & home-office allocation
• rebuild imported-item self-assessment
• prepare CPA-certified CRA audit binder
• negotiate reduction of penalties & arrears

Learning insight: These audits are won through service classification accuracy + clean logs + strong ITC evidence.

Common CRA Findings in ABA & Support-Worker Audits

• GST/HST not charged on sessions
• behavioural services incorrectly labeled “healthcare”
• subcontractor invoices missing or invalid
• ITCs denied for missing receipts
• bank deposits > declared revenue
• personal-use toys, tools & supplies claimed
• imported sensory tools missing GST
• travel fees not taxed
• home-program packages not itemized

Learning insight: CRA reassessments often exceed $100,000+ in this industry due to exemption misunderstandings.

Real-World Results

• An ABA tutor avoided a $168,000 reassessment after Mackisen CPA proved services were misclassified by CRA’s automated system and rebuilt all logs.
• A special-needs support company reversed a $121,000 ITC denial through full documentation of sensory tools & mileage proof.
• A shadow-teaching contractor eliminated penalties by correcting GST/HST on all support sessions.
• A respite-care provider cleared CRA findings through deposit→invoice→log reconciliation.

Learning insight: CRA backs down when classification and documentation are CPA-organized and irrefutable.

SEO Optimization & Educational Value

Primary keywords: GST/HST ABA audit, CRA autism therapy audit, developmental support GST rules Canada, Mackisen CPA Montreal
Secondary keywords: PSW vs ABA GST, taxable behavioural therapy, autism support ITC denial, subcontractor ABA audit

Learning insight: Demand is exploding for guidance in this niche — extremely strong SEO potential.

Why Mackisen CPA Montreal

With 35+ years defending ABA workers, autism-support contractors, shadow teachers & developmental support agencies, Mackisen CPA Montreal is Québec’s leading authority in GST/HST audits for non-regulated health-support sectors.

We understand behavioural-program workflows, service classification, subcontractor risks, ITC allocation, and CRA’s audit methodology deeply.

Learning insight: ABA & support-service audits require classification clarity, log discipline, subcontractor compliance & ITC rigor — all strengths of Mackisen CPA.

Call to Action

If CRA is auditing your ABA practice, autism-support service, shadow teaching, respite care, or developmental home-program business, contact Mackisen CPA Montreal immediately:

📞 514-276-0808
📧 info@mackisen.com
🌐 mackisen.com

Learning Conclusion:

A CRA GST/HST ABA & Support-Service Audit tests service classification (exempt vs taxable), subcontractor GST compliance, ITC documentation, travel-fee GST, and log accuracy.
Mackisen CPA Montreal ensures full audit protection.