CRA GST/HST Renovation Cleaning, Post-Construction Cleaning & Site Cleanup Audit — Montreal CPA Firm Near You: Defending Cleanup Services, Labour, Subcontractors & ITCs

A CRA GST/HST Post-Construction Cleaning & Site Cleanup Audit targets businesses providing:

• post-construction cleaning
• renovation cleanup
• debris removal
• site sweeping
• drywall dust removal
• paint/floor residue cleanup
• pre-occupancy cleaning
• move-in/move-out cleaning for new-builds
• commercial turnover cleaning
• heavy construction cleanup crews
• subcontracted cleanup services for general contractors

This industry faces extremely high audit risk because cleanup companies are often subcontractors on construction sites, operate largely in cash or e-transfer, have inconsistent invoicing practices, and regularly mix taxable cleaning services with taxable labour — leaving no exempt components.

Mackisen CPA Montreal specializes in defending construction-cleanup audits through job-level reconstruction, subcontractor validation, equipment ITC documentation, and CRA-ready audit binders.

Legal Foundation

Excise Tax Act

• s.165 — ALL cleaning, labour, and post-construction services are fully taxable

• s.221 — requirement to collect/remit GST/HST

• s.169 — ITC eligibility requires complete invoices + proof of payment

• s.141.01 — allocation rules for mixed-use supplies

• Schedule IX — place-of-supply rules for QC/ON/Atlantic construction jobs

• s.286 — strict recordkeeping requirements

Case Law

• Royal Bank v. Canada — incomplete invoices = no ITCs

• Northwest Company Inc. — ITC denial for invoice defects

• CGI v. Canada — service tax rate follows province where site work occurs

• CRA rulings confirm: construction cleaning is 100% taxable (no exemptions).

Learning insight: There is no such thing as exempt post-construction cleaning — every activity is taxable under GST/HST law.

Why CRA Audits Post-Construction Cleaning Companies

CRA targets this segment when it detects:

Revenue Risks

• GST/HST not charged on renovation or construction cleanup
• subcontract work paid in cash or e-transfer without invoices
• multi-phase cleaning (rough clean, final clean) not documented
• inconsistent contract amounts vs deposits
• materials included but not taxed
• out-of-province cleanup projects charged wrong GST/HST
• last-minute contractor payments not reflected in GST returns
• general contractors issuing T5018 slips inconsistent with GST filings

Subcontractor Risks

• subcontractors using invalid or missing GST numbers
• incomplete subcontractor invoices
• employee vs subcontractor misclassification
• cash payments to crews

ITC Risks

• missing invoices for:
– cleaning solutions & chemicals
– PPE & gloves
– vacuums & heavy-duty cleanup tools
– mops, buckets, squeegees
– garbage bags, disposal fees
– truck expenses
• ITCs denied because of missing proof of payment
• imported equipment missing s.218 GST self-assessment
• personal supplies claimed as business

Operational Risks

• no job logs
• constant subcontractor rotation
• missing work orders from general contractors
• inconsistent cleanup schedules
• “rush jobs” not invoiced
• poor bookkeeping

High-risk businesses include:

• construction cleanup crews

• renovation cleanup specialists

• commercial turnover cleaning

• heavy-duty cleanup contractors

• multi-unit residential build cleanup teams

• subcontract cleaning companies

Learning insight: CRA automatically suspects underreported revenue + invalid ITCs + subcontractor non-compliance in this industry.

CRA Cleanup Audit Process

1. CRA requests:
   – invoices (labour, material, disposal)
   – subcontractor invoices & GST numbers
   – cleanup contracts & work orders
   – job logs (dates, addresses, crews)
   – T5018 summaries from general contractors
   – bank statements + e-transfer logs
   – waste disposal invoices
   – PPE & supply invoices
   – vehicle & fuel receipts
   – ITC spreadsheets
   – equipment purchase invoices

2. CRA tests:
   • GST/HST applied correctly on all cleanup activities
   • subcontractor registration & invoice validity
   • ITC proof-of-payment
   • job logs vs deposits vs GST returns
   • disposal fees taxed correctly
   • place-of-supply for out-of-province cleaning
   • personal vs business tool/equipment use

3. CRA issues a Proposed Audit Adjustment.

4. Mackisen CPA prepares comprehensive documentary + legal defense.

Learning insight: CRA uses sampling + extrapolation — one improper invoice can trigger year-wide reassessments.

Mackisen CPA’s Cleanup Audit Defense Strategy

• create a Clean-Up Supply Tax Matrix (labour, materials, disposal, travel)
• rebuild complete GST-compliant invoices
• validate subcontractor GST registration
• reconstruct ITC binder:
– supplies
– PPE
– tools
– equipment
– vehicles
– waste disposal
• reconcile job logs → deposits → GST returns
• defend disposal and waste-handling charges
• correct QC/ON/Atlantic place-of-supply GST/HST rules
• prepare CRA-ready CPA-certified audit binder
• negotiate penalty and interest reductions

Learning insight: Cleanup companies win audits through job-by-job evidence, valid invoices, subcontractor compliance, and ITC discipline.

Common CRA Findings in Cleanup Audits

• GST/HST not charged on:
– rough cleans
– deep cleans
– final cleans
– waste removal
– travel/mileage
• subcontractor invoices invalid or missing
• ITCs denied due to missing proof of payment
• personal-use supplies claimed
• cash/e-transfer receipts underreported
• disposal fees untaxed
• bank deposits exceed reported revenue
• multi-province tax errors
• imported cleaning equipment without self-assessment

Learning insight: CRA’s largest reassessments come from invoice deficiencies + subcontractor issues + missing ITC proof.

Real-World Results

• A renovation cleanup business avoided a $241,000 reassessment after Mackisen CPA rebuilt subcontractor and ITC documentation.
• A heavy-duty construction-cleanup crew reversed a $129,000 ITC denial after complete invoice and payment reconstruction.
• A post-construction cleaning group eliminated penalties by correcting GST/HST on disposal fees and multi-province contracts.
• A commercial turnover cleaning company cleared CRA findings through calendar→invoice→deposit reconciliation.

Learning insight: CRA backs down once cleanup operations show organized, CPA-certified documentation.

SEO Optimization & Educational Value

Primary keywords: GST/HST post-construction cleaning audit, CRA renovation cleanup audit, taxable cleaning services Canada, Mackisen CPA Montreal
Secondary keywords: cleanup ITC denial, subcontractor GST audit, construction site cleaning GST/HST, disposal fee GST rules

Learning insight: Construction-cleaning GST audits are a growing audit category — strong SEO opportunity.

Why Mackisen CPA Montreal

With 35+ years defending construction-related cleaning companies, Mackisen CPA Montreal is Québec’s #1 authority in GST/HST audit defense for renovation and post-construction cleanup providers.
We understand trade-level operations, subcontractor networks, equipment usage, material flows, and CRA investigation methods.

Learning insight: Cleanup audits require documentation depth + subcontractor verification + tax logic integrity — all strengths of Mackisen CPA.

Call to Action

If CRA is auditing your renovation cleanup business, post-construction cleaning crew, waste removal, or ITC claims, contact Mackisen CPA Montreal immediately:

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

Learning Conclusion:

A CRA GST/HST Post-Construction Cleaning Audit tests service taxability, subcontractor compliance, job-log accuracy, disposal fees, and ITC documentation.
Mackisen CPA Montreal ensures your entire cleanup operation is fully defended from reassessments.