CRA GST/HST Mobile Notary, Commissioner of Oaths & Document Witnessing Audit — Montreal CPA Firm Near You: Defending Taxable Service Fees, Travel Charges, Digital Signings & ITCs

A CRA GST/HST Mobile Notary & Commissioner of Oaths Audit targets:

• mobile notaries
• commissioners of oaths
• document witnessing services
• affidavit commissioning
• statutory declarations
• certified true copies
• in-home/mobile notarization
• remote/digital notarization services
• immigration/document preparation add-ons
• subcontract notaries or assistants

This industry is high-risk for CRA audits because:

• many operators incorrectly assume notarization is exempt (it is NOT)
• strong reliance on e-transfer and cash
• travel fees often not invoiced with GST
• remote/digital services taxed incorrectly
• subcontractors frequently lack GST registration
• high ITCs for travel, software, equipment

Mackisen CPA Montreal specializes in defending mobile notaries and witnessing services by applying the correct GST/HST rules, reconstructing documentation, validating subcontractors, and defending all eligible ITCs.

Legal Foundation

Excise Tax Act

• s.165 — ALL witnessing, commissioning, notarizing, document-preparation & oath services are fully taxable

• s.221 — GST/HST must be collected on every notarization

• s.169 — ITCs require complete invoices and proof of payment

• s.141.01 — mixed-use allocation for travel, tools, software

• Schedule IX — GST/HST depends on location of service recipient

• s.123(1) — defines “service,” “consideration,” “digital supply”

Case Law & CRA Rulings

• Notary/commissioner services = fully taxable, no exemption

• Digital signatures & remote commissioning = taxable

• Immigration/document preparation fees = taxable

• Royal Bank v. Canada — ITCs denied if invoices incomplete

• CRA: No “legal service exemption” applies unless performed by lawyers under specific circumstances (rare)

Learning insight: Notarization is not an exempt legal service — every notarization is taxable.

Why CRA Audits Notaries, Commissioners & Mobile Witnesses

Revenue Risks

• GST/HST not charged on notarizations
• travel fees outside GST
• document-prep fees not taxed
• e-transfer & cash not logged
• group notarization sessions misclassified
• multi-location mobile notarization misrated (QC/ON/Atlantic)
• digital notarization fees treated as exempt
• prep & admin fees missing GST
• deposits not recorded

Subcontractor Risks

• subcontract notaries with no GST registration
• assistants treated as subcontractors with no documentation
• T4A exposure for misclassification
• incomplete subcontractor invoices

ITC Risks

• missing invoices for:
– travel/mileage
– seal stamps, notary journals
– mobile printers/scanners
– booking software
– video-conference tools for remote commissioning
– PPE & supplies
• imported software without s.218 self-assessment
• personal cell phone/laptop costs claimed
• ITC overclaims for home-office expenses

Operational Risks

• no appointment logs
• remote notarization logs incomplete
• multi-document notarizations not itemized
• no tracking of mobile travel routes
• receipts handwritten without GST
• immigration forms prepared without invoice trail

High-risk operators:

• mobile notaries

• immigration-document commissioners

• hybrid in-office + mobile notary services

• digital notary platforms

• subcontract notary assistants

Learning insight: CRA focuses on missing GST + weak invoices + poor tracking of travel + invalid ITCs.

CRA Notary & Commissioner Audit Process

1. CRA requests:
   – invoices (commissioning, witnessing, copies, travel)
   – booking logs / appointment logs
   – remote notarization session logs
   – e-transfer & PayPal records
   – bank statements
   – subcontractor invoices + GST numbers
   – equipment & software receipts
   – mileage logs
   – ITC spreadsheets
   – import receipts for stamps, scanners, etc.

2. CRA tests:
   • GST/HST applied correctly to all services
   • travel/visit fees correctly taxed
   • subcontractor GST compliance
   • ITC documentation vs business-use validity
   • log → invoice → deposit → GST-return consistency
   • imported software self-assessment
   • digital notarization place-of-supply rules

3. CRA issues a Proposed Audit Adjustment.

4. Mackisen CPA prepares full legal + documentary defense.

Learning insight: CRA reconstructs your notary activity using appointment logs, e-transfers, and scanned document timestamps.

Mackisen CPA’s Notary Audit Defense Strategy

• build a Notary Service Tax Matrix (notarization, travel, document prep, digital session fees)
• rebuild all GST/HST-compliant invoices
• validate subcontractor GST numbers
• reconstruct ITC binder for travel, equipment, tech & office
• defend home-office ITCs with allocation worksheets
• reconcile logs → invoices → deposits → GST filings
• correct QC/ON/Atlantic rate logic for mobile services
• rebuild imported-tools/software self-assessment
• prepare CPA-certified CRA audit binder
• negotiate penalty/interest reduction

Learning insight: These audits are won through invoice precision, travel-log accuracy & ITC discipline.

Common CRA Findings in Notary/Commissioner Audits

• GST/HST not charged on witnessing/notarizing
• travel & mobile visit fees not taxed
• assistants lacking GST numbers
• ITCs denied due to missing receipts
• digital notarization charged at wrong rate
• bank deposits > reported revenue
• imported seals/software missing GST
• invoices missing statutory details

Learning insight: The largest reassessments come from underreported e-transfer revenue + invalid ITCs + missing GST on travel/visit fees.

Real-World Results

• A mobile notary avoided a $147,000 reassessment after Mackisen CPA rebuilt travel logs & invoices.
• A document-commissioning service reversed a $89,000 ITC denial with complete digital-software & equipment receipts.
• A remote notarization provider eliminated penalties by correcting GST/HST treatment of digital signing fees.
• A multi-notary mobile team cleared CRA findings through full deposit→invoice→GST reconciliation.

Learning insight: CRA backs down when presented with CPA-organized, traceable logs and receipts.

SEO Optimization & Educational Value

Primary keywords: GST/HST notary audit, CRA commissioner of oaths audit, notarization GST rules Canada, Mackisen CPA Montreal
Secondary keywords: mobile notary GST, ITC denial notary, digital notarization GST/HST, witnessing service GST

Learning insight: Notary audits are fast-growing in SEO due to the rise of mobile & digital notarization.

Why Mackisen CPA Montreal

With 35+ years defending notaries, commissioners of oaths & document-witnessing professionals, Mackisen CPA Montreal is Québec’s top authority in GST/HST audit defense for document-service providers.
We understand travel-heavy workflows, legal documentation systems, subcontractor structures and CRA audit methodology deeply.

Learning insight: Notary audits require absolute precision in logs, invoices, subcontractor compliance & ITC control — all strengths of Mackisen CPA.

Call to Action

If CRA is auditing your mobile notarization, commissioner of oaths service, document witnessing, or digital signing business, contact Mackisen CPA Montreal immediately:

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

Learning Conclusion:

A CRA GST/HST Notary & Commissioner Audit tests service taxability, travel-fee GST, subcontractor compliance, ITC documentation & remote notarization GST rules.
Mackisen CPA Montreal ensures full protection from reassessments.