Insight
Nov 26, 2025
Mackisen

CRA GST/HST Real Estate Rental Rebate Audit — Montreal CPA Firm Near You: Defending NRRPR Claims, Tenant Occupancy, and Rental Intention

A CRA GST/HST Real Estate Rental Rebate Audit targets the New Residential Rental Property Rebate (NRRPR). CRA audits these rebates aggressively because rental rebates are frequently misunderstood, misfiled, or insufficiently documented — especially for newly constructed homes, condo rentals, assignment purchases, Airbnb conversions, and mixed-use properties.
Mackisen CPA Montreal specializes in defending rental rebate audits by proving long-term rental intention, tenant occupancy, and correct GST/HST treatment under the Excise Tax Act. We prepare complete CPA-certified audit binders to protect your rebate from denial or clawback.
Legal Foundation
Excise Tax Act s.256.2 — governs the New Residential Rental Property Rebate (NRRPR).
Excise Tax Act s.191 — requires self-assessment on new residential rental conversions.
Excise Tax Act s.123(1) — defines “residential complex,” “builder,” and “rental use.”
Case law:
• Cheema v. Canada — beneficial ownership and intention matter.
• Tarnowe — occupancy must be proven for rebate eligibility.
• Chella — CRA can deny rebates when rental intention is unclear.
Learning insight: CRA requires proof of genuine long-term rental use, not just a lease document.
Why CRA Audits Rental Rebates
CRA flags NRRPR claims when it detects:
• new-build condos purchased and immediately rented
• assignment purchases where rebates were incorrectly claimed
• rental rebate claimed but the unit was vacant or short-term rented
• evidence of Airbnb or short-term stays
• landlord unable to show long-term rental intent
• mismatch between lease start date and occupancy
• corporation holding the property → suspected business activity
• missing or inconsistent documentation (ads, leases, utility bills)
Learning insight: CRA denies rebates when there’s any ambiguity about rental use or timeline.
CRA Rental Rebate Audit Process
CRA requests:
– lease agreements
– rental ads and applications
– tenant IDs and contact info
– hydro/utility usage
– insurance records
– closing documents
– mortgage statements
– rental deposit receipts
– Airbnb logs (if applicable)CRA reconstructs the intention timeline:
purchase → completion → occupancy → rental useCRA tests rebate eligibility under s.256.2.
CRA checks for missing self-assessment on conversion.
CRA issues proposed reassessment.
Mackisen CPA responds with full evidentiary defense.
Learning insight: The rebate depends on intention + occupancy + long-term rental proof.
Mackisen CPA’s NRRPR Audit Defense Strategy
• prove long-term rental intention using ads, agent emails, applications, and screening logs
• document actual occupancy with utility consumption, tenant IDs, insurance, and bank deposits
• defend against improper “builder classification”
• ensure proper GST/HST self-assessment calculations were completed
• isolate short-term rental activity from long-term use
• prepare CPA-certified rental rebate binders
• reconstruct missing documentation (leases, payments, communication)
• negotiate lower reassessment based on corrected facts
Learning insight: CRA backs down when the rental story is coherent, documented, and timeline accurate.
Common CRA Findings in Rental Rebate Audits
• rebate denied for lack of tenant occupancy
• Airbnb activity → rebate cancelled
• rental intention questioned due to long vacancy
• GST/HST self-assessment missing at conversion
• assignment purchaser not eligible for rebate
• builder misclassification → unit treated as inventory
• incorrect filing on Form GST524
• corporate ownership treated as commercial flip
Learning insight: Almost all findings arise from documentation gaps, not wrongdoing.
Real-World Results
• A landlord kept a $31,000 rental rebate after Mackisen CPA proved long-term rental intention despite a 45-day vacancy.
• A condo investor avoided a $72,000 reassessment when we showed that Airbnb activity occurred only during tenant transition and corrected self-assessment filings.
• An assignment purchaser preserved rebate eligibility by demonstrating beneficial ownership transfer timing.
• A corporate landlord overturned CRA’s claim of builder classification with a complete rental-use timeline.
Learning insight: The better your evidence, the weaker CRA’s assumptions become.
SEO Optimization and Educational Value
Primary keywords: GST/HST rental rebate audit, CRA NRRPR audit, rental rebate denial, Mackisen CPA Montreal, GST rental audit
Secondary keywords: long-term rental proof, GST rebate documentation, builder classification rental, CRA rental reassessment
Learning insight: Rental rebate topics are highly searched — authoritative explanations drive SEO performance.
Why Mackisen CPA Montreal
With 35+ years in real estate GST/HST defense, Mackisen CPA Montreal is Québec’s leading authority on the New Residential Rental Property Rebate. Our bilingual CPAs know exactly how CRA tests intention, occupancy, builder status, and rental timelines, and we prepare bulletproof documentation to protect your rebate.
Learning insight: Rental rebate audits are timeline and documentation audits — we win both.
Call to Action
If CRA is auditing your rental rebate, assignment rebate, or builder classification, get professional defense immediately.
Contact Mackisen CPA Montreal for full NRRPR audit defense and documentation reconstruction.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com
Learning conclusion: A CRA GST/HST Real Estate Rental Rebate Audit tests rental intention, occupancy, and eligibility. Mackisen CPA Montreal ensures every condition is proven and defended — protecting your rebate and preventing six-figure reassessments.

