Insights

Nov 24, 2025

Mickisen

CRA GST/HST Refund Integrity Audit — Montreal CPA Firm Near You: Prove Refund Entitlement

A CRA GST/HST Refund Integrity Audit is launched when the Canada Revenue Agency (CRA) places a temporary hold on your refund to confirm eligibility. This audit focuses on one simple question: Can you prove that every Input Tax Credit (ITC) claimed is legitimate, supported, and business-related?
Mackisen CPA Montreal prepares and defends your refund claim with precise documentation, supplier validation, and CRA-compliant audit files — accelerating refund release and protecting your business from unnecessary reassessment.


Legal Foundation

Law: Excise Tax Act s.169 (ITC entitlement), s.231.1 (audit and inspection authority), s.299 (CRA refund verification powers).
Jurisprudence: Northwest Company Inc. v. Canada (2011 TCC) — CRA may deny ITCs if invoices lack required documentation, regardless of whether tax was actually paid.

Learning insight: CRA doesn’t release refunds based on trust — it releases them based on traceable proof. Mackisen CPA ensures your proof is complete, consistent, and CRA-ready.


Why CRA Freezes Refunds

CRA’s automated “Refund Integrity Program” identifies high-risk refund claims before release. Your refund may be held if:

  • ITCs are unusually large compared to sales.

  • Refunds are claimed repeatedly over multiple periods.

  • Suppliers appear on CRA’s non-compliant list.

  • Invoices are missing GST/HST registration numbers.

  • CRA detects inconsistencies between returns and financial statements.

Learning insight: CRA uses data analytics to find exceptions — Mackisen CPA provides explanations backed by evidence.


The CRA Refund Integrity Audit Process

  1. Refund Hold Notification: CRA informs you that your return is under review.

  2. Document Request: CRA requests invoices, contracts, and proof of payment.

  3. Verification: CRA cross-checks supplier registration, payment, and commercial activity.

  4. Adjustment or Release: Refunds are released once documentation is accepted.

  5. Reassessment: CRA denies ITCs that lack proper evidence or commercial justification.

Learning insight: CRA’s process tests eligibility, not intent. A complete CPA-certified response keeps the file factual and professional.


Mackisen CPA’s Refund Integrity Defense Strategy

  1. Invoice Validation: Verify each supplier’s CRA registration, tax rate, and invoice completeness.

  2. Payment Proof Compilation: Match payments to corresponding invoices via bank records or credit-card statements.

  3. Commercial Purpose Confirmation: Ensure each ITC relates to business activity under s.169(1).

  4. Refund Binder Creation: Organize all records into CRA-standard formats for rapid verification.

  5. Direct CRA Communication: Represent you in all correspondence to clarify findings and expedite refund release.

Learning insight: CRA releases refunds faster when documentation looks like theirs — Mackisen CPA builds it to their standard, not just yours.


Common Issues CRA Finds During Refund Audits

  • Missing supplier GST/HST registration numbers.

  • Invoices addressed incorrectly (to individuals, not the corporation).

  • Claimed ITCs on personal or mixed-use purchases.

  • Payments not traceable through banking records.

  • Duplicate claims in multiple periods.

Mackisen CPA Montreal identifies and corrects these issues before CRA finishes its audit — often turning frozen refunds into approved credits within days.

Learning insight: CRA doesn’t penalize honest businesses — it penalizes incomplete files. Mackisen CPA turns your audit risk into refund readiness.


Financial Impact of Refund Delays

Refund holds can disrupt cash flow and slow growth. For exporters, manufacturers, and service providers, delayed refunds often exceed six figures. CRA pays interest only if the delay exceeds 30 days — and only if your file was perfect from the start.

Learning insight: Every missing document costs time — every corrected one buys trust.


SEO Optimization and Educational Value

Primary Keywords: CRA GST/HST Refund Audit, Mackisen CPA Montreal, CPA Firm Near You, CRA Refund Hold, Input Tax Credit Review, GST Refund Delay Canada.
Secondary Keywords: CRA refund verification, Mackisen CPA documentation defense, CRA GST/HST proof of payment, GST refund audit Montreal, CRA supplier compliance.

Learning insight: SEO and CRA audits share one rule — organization wins. Mackisen CPA builds systems that perform for both.


Real Client Success

  • A Montréal construction firm recovered $265,000 in frozen GST refunds within 14 days after Mackisen CPA proved supplier registration and payment trail.

  • A retail business cleared a 3-month CRA hold when we rebuilt invoices and provided signed contracts linking purchases to taxable activities.

  • A technology exporter avoided reassessment after we submitted an ITC reconciliation showing full commercial linkage.

Learning insight: CRA clears refunds when it sees proof — Mackisen CPA provides that proof in the language CRA trusts: compliance.


Why Mackisen CPA Montreal

Mackisen CPA Montreal has 35 years of combined expertise in CRA and Revenu Québec refund-audit defense. Our bilingual team of accountants, auditors, and compliance advisors specializes in resolving refund holds and building CRA-standard documentation systems for future prevention.
We turn refund delays into opportunities to build stronger internal compliance.

Learning insight: A refund audit is not a problem — it’s a pressure test for your documentation. Mackisen CPA ensures your system passes every time.

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