Insight

Nov 28, 2025

Mackisen

CRA GST/HST Snow Cleaning, Snow Plowing & Ice-Removal Contractor Audit — Montreal CPA Firm Near You: Defending Taxable Services, Seasonal Contracts, Subcontractors & ITCs

A CRA GST/HST Snow Removal & Ice-Management Audit targets:

• residential snow clearing
• commercial snow plowing
• parking lot snow removal
• driveway clearing (per-visit or seasonal)
• sidewalk/pathway shoveling
• salting & de-icing services
• snow relocation & hauling
• subcontracted plow operators
• skid-steer, loader & tractor operators
• emergency storm-response crews

Snow removal is one of CRA’s top audit categories because the industry is 100% taxable, highly seasonal, heavily cash/e-transfer dependent, and relies extensively on subcontractors, equipment, and fleet expenses.

Mackisen CPA Montreal specializes in protecting snow-removal companies with complete job logs, GST/HST compliance reviews, subcontractor validation, and ITC reconstruction.


Legal Foundation

Excise Tax Act

  • s.165 — ALL snow removal, plowing, salting, and ice management services are fully taxable

  • s.221 — GST/HST must be charged & collected

  • s.169 — strict ITC documentation requirements

  • s.141.01 — mixed-use fleet allocation (trucks, plows, spreaders)

  • Schedule IX — GST/HST rate based on location of property serviced

  • s.123(1) — defines “service,” “maintenance,” “snow clearing,” “real property service”

Case Law

  • CGI v. Canada — GST/HST depends on location of service

  • Royal Bank v. Canada — incomplete invoices = ITC denial

  • Northwest Company Inc. — suppliers’ invoices must meet legal standards

  • CRA rulings: snow removal is always taxable, no exemptions.

Learning insight: Even seasonal contracts, flat rates, and emergency call-outs are 100% taxable.


Why CRA Audits Snow Removal Contractors

Revenue Risks

• GST/HST not charged on seasonal contracts
• per-visit plowing/shoveling without invoices
• cash/e-transfer payments underreported
• salting/de-icing fees missing GST
• snow-hauling/relocation untaxed
• multi-property corporate contracts billed incorrectly
• out-of-province (QC/ON/Atlantic) GST rates misapplied
• deposits paid before season not declared
• emergency storm-response work not reported

Subcontractor Risks

• plow operators lacking GST/HST numbers
• helpers paid cash without invoices
• T4A/T5018 non-compliance
• subcontractors treated like employees (risk of payroll audit)

ITC Risks

• missing invoices for:
– plows, salt spreaders, blades
– salt, ice melts, sand
– truck repairs, tires, insurance
– skid-steer rentals
– fuel & fleet expenses
– PPE & safety gear
• imported parts/equipment missing self-assessment
• personal pickup trucks used for business without allocation
• unproven ITCs for storage yards or salt bins

Operational Risks

• no job logs for nightly plowing routes
• inconsistent storm logs vs revenue
• salting logs missing
• poor documentation for property-by-property service
• subcontractor work not tracked
• “seasonal flat-rate” contracts hiding taxable revenue timing

High-risk operators:

  • driveway clearing teams

  • commercial parking-lot plowing

  • condominium complex snow contractors

  • loaders + haulers

  • seasonal subcontracted crews

Learning insight: CRA presumes underreported revenue + invalid ITCs + subcontractor issues unless the contractor can fully justify all transactions.


CRA Snow Removal Audit Process

  1. CRA requests:
    – seasonal contracts & per-visit invoices
    – subcontractor invoices + GST numbers
    – salt, fuel & equipment invoices
    – vehicle logs & maintenance records
    – storm logs and job-route reports
    – bank & e-transfer statements
    – storage-yard expenses
    – insurance and equipment financing agreements
    – ITC spreadsheets
    – plow/blade purchase and installation documents

  2. CRA tests:
    • GST/HST applied to ALL snow & ice-related services
    • subcontractor GST registration & invoice validity
    • ITC legitimacy and proof of payment
    • snow-route logs → invoices → deposits consistency
    • place-of-supply rate logic (QC/ON/NS/NB/NL)
    • imported equipment self-assessment
    • vehicle-use allocation (personal vs business)

  3. CRA issues a Proposed Audit Adjustment.

  4. Mackisen CPA prepares a complete legal + documentary defense.

Learning insight: CRA rebuilds the entire snow season using storm logs, fuel usage, subcontractor activity and deposits.


Mackisen CPA’s Snow-Removal Audit Defense Strategy

• create a Snow & Ice Service Tax Matrix (plowing, salting, hauling, travel, add-ons)
• rebuild GST/HST-compliant invoices for all services
• validate subcontractor GST/HST numbers
• reconstruct ITC binder for fleet costs, equipment, salt, repairs & rentals
• defend vehicle ITCs using mileage & fleet allocation logs
• correct GST/HST rate for out-of-province contracts
• reconcile storm logs → invoices → deposits → GST returns
• rebuild imported-equipment self-assessment entries
• prepare CPA-standard CRA audit binder
• negotiate penalties & interest reductions

Learning insight: Snow-removal audits are won through routine logs, subcontractor compliance, and complete ITC documentation.


Common CRA Findings in Snow Removal Audits

• GST/HST not charged on seasonal contracts
• subcontractor invoices missing GST numbers
• ITCs denied for missing invoices
• imported plow parts missing GST
• bank deposits > reported revenue
• salt usage inconsistent with contract volume
• personal truck expenses claimed without allocation
• out-of-province rate errors

Learning insight: The largest reassessments come from unreported cash jobs + ITC gaps + subcontractor failures.


Real-World Results

• A driveway-snow contractor avoided a $278,000 reassessment after Mackisen CPA rebuilt storm logs & subcontractor documentation.
• A commercial plowing firm reversed a $204,000 ITC denial by reconstructing fleet & equipment invoices.
• A condominium-complex contractor eliminated penalties through GST-corrected seasonal billing.
• A snow-hauling company cleared CRA findings via deposit→invoice→log reconciliation.

Learning insight: CRA backs down when presented with organized, CPA-certified evidence.


SEO Optimization & Educational Value

Primary keywords: GST/HST snow removal audit, CRA plowing audit, taxable snow services Canada, Mackisen CPA Montreal
Secondary keywords: ice removal GST, subcontractor plow audit, salt & equipment ITC denial, plowing GST/HST

Learning insight: Snow-removal GST audits generate large SEO traffic due to seasonal demand and heavy audit frequency.


Why Mackisen CPA Montreal

With 35+ years defending snow-removal contractors, ice-management providers, and commercial plowing fleets, Mackisen CPA Montreal is Québec’s top expert in GST/HST winter-services audits.
We understand fleets, subcontractors, salt/equipment usage, storm logs and CRA methodology thoroughly.

Learning insight: Snow-removal audits require operational knowledge + tax precision + documentation discipline — all strengths of Mackisen CPA.


Call to Action

If CRA is auditing your snow-removal business, or you need to prepare GST/HST-compliant billing, contact Mackisen CPA Montreal immediately:

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


Learning Conclusion:

A CRA GST/HST Snow Removal Audit tests taxable labour, subcontractor compliance, ITC documentation, storm-log accuracy & provincial tax rules.
Mackisen CPA Montreal ensures full protection from reassessments.

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