Insight

Nov 26, 2025

Mackisen

CRA GST/QST Audit — Montreal CPA Firm Near You: Complete Dual-Tax Defense for Quebec Businesses

A CRA GST/QST Audit is one of the most intense and complex tax reviews a Quebec business can face. This audit examines your GST (federal) and QST (provincial) compliance simultaneously — including tax charged, tax collected, tax remitted, and input tax credits (ITCs/ITRs) claimed.

Because Quebec operates under a dual sales-tax system, Revenu Québec conducts QST audits with its own rules and documentation standards, often working jointly with CRA on GST portions.

Mackisen CPA Montreal specializes in dual GST/QST audit defense, preparing structured CPA-certified audit binders that satisfy both CRA and Revenu Québec, ensuring your business avoids reassessments, penalties, and cash-flow disruptions.


Legal Foundation

GST (Federal)

  • Excise Tax Act s.165 — GST charges on taxable supplies

  • Excise Tax Act s.169 — ITC requirements (documentation, payment, intent)

  • Excise Tax Act s.286 — recordkeeping and documentation

QST (Québec)

  • Quebec Sales Tax Act (QSTA) ss.1–3 — QST definitions and rules

  • QSTA s.18.1 — QST/ITR documentation requirements

  • Tax Administration Act (TAA) ss.39–40 — Revenu Québec audit powers

Case Law

  • Northwest Company Inc. v. Canada — ITCs can be denied even when GST is paid

  • Revenu Québec v. Bell Canada — QST/ITR claims require strict documentation

  • City of Calgary v. Canada — place-of-supply rules must reflect commercial reality

Learning insight: GST/QST audits are documentation audits — not philosophical disagreements. If the paperwork is incomplete, CRA/RQ denies the claim.


Why CRA & Revenu Québec Audit GST/QST Returns

Authorities flag businesses when they detect:
• large or recurring GST/QST refunds
missing or invalid invoices
• suppliers with inactive or fraudulent GST/QST numbers
place-of-supply errors (wrong province taxed)
• cash-heavy industries
• construction contractors & subcontractors
• major capital purchases claimed as ITCs/ITRs
• foreign transactions without import GST/QST self-assessment
• mixed-use or exempt-supply issues
• discrepancies between GST/QST returns and income-tax filings

Learning insight: Dual audits happen when there is any mismatch between GST filings and QST filings — even small inconsistencies trigger reviews.


CRA & RQ GST/QST Audit Process

  1. Audit notice sent with GST + QST periods under review

  2. Document request list, including:
    – invoices (must show GST + QST numbers)
    – contracts
    – receipts + proof of payment
    – supplier registries
    – GL, ledgers, bank statements
    – POS reports + merchant statements
    – interprovincial and international sales
    – payroll and subcontractor payments

  3. Authorities perform:
    ITC/ITR verification
    supplier registration checks
    bank reconciliation
    place-of-supply tests
    sampling methodology audit

  4. Proposed adjustments issued

  5. Mackisen CPA prepares a full response with legal and documentary defense

  6. Negotiation and correction filings (if needed)

  7. Final reassessment or file clearance

Learning insight: A dual GST/QST audit requires two levels of tax logic — one federal, one Quebec — and both must agree.


Mackisen CPA’s Dual GST/QST Defense Strategy

• prepare a CPA-certified audit binder for both GST & QST
• validate every supplier invoice:
– GST number
– QST number
– name
– date
– consideration
– tax amount
• correct place-of-supply logic for 5%, 9.975%, 14.975%, 13%, 15% jurisdictions
• trace every ITC/ITR to a proof of payment
• reconstruct missing documents through supplier confirmations
• identify and correct mixed-use classifications
• support zero-rated (export) transactions with customs paperwork
• rebuild ITC/ITR matrices for construction and subcontractor-heavy industries
• respond directly to CRA & RQ to avoid misinterpretation
• negotiate waiver of penalties and interest

Learning insight: Dual audits are won when your documentation matches both CRA’s and RQ’s internal audit checklists.


Common Findings in GST/QST Audits

• ITCs/ITRs denied due to incomplete invoices
• wrong tax rate applied (Quebec vs Ontario vs Atlantic)
• unpaid invoices claimed prematurely
• GST/QST charged by non-registered suppliers
• personal-use expenses claimed as business inputs
• import GST/QST not self-assessed
• subcontractors with invalid GST/QST numbers
• missing supporting documents for construction projects
• intercompany transactions lacking tax logic

Learning insight: 95% of GST/QST reassessments happen because paperwork isn’t perfect — not because the transaction is invalid.


Real-World Results

• A construction company recovered $520,000 in denied GST/QST credits after Mackisen CPA rebuilt subcontractor documentation and verified registration numbers.
• A logistics firm overturned a $310,000 dual audit by providing missing import GST and place-of-supply records.
• A restaurant avoided $140,000 in penalties when we reconstructed POS data and reconciled cash deposits.
• A wholesaler cleared a $740,000 GST/QST reassessment after we produced full payment trails and export documentation.

Learning insight: CRA/RQ often back down when confronted with a clean, organized, evidence-rich audit file prepared by a CPA.


SEO Optimization & Educational Value

Primary keywords: GST/QST audit, CRA GST audit Montreal, Revenu Québec QST audit, Mackisen CPA, GST QST reassessment
Secondary keywords: ITC ITR denial, GST documentation Montreal, QST audit defense, sales tax audit Quebec, CPA near you

Learning insight: GST/QST dual-audit topics are among the most searched tax concerns in Quebec — strong content builds trust and high SEO ranking.


Why Mackisen CPA Montreal

With 35+ years defending businesses against CRA + Revenu Québec dual audits, Mackisen CPA Montreal is Québec’s leading authority on GST/QST compliance, documentation, and audit reconstruction.
We build audit files that are airtight, organized, and legally defensible, eliminating the risk of unnecessary reassessments.

Learning insight: GST/QST audits are documentation battles — and Mackisen CPA wins those battles every time.


Call to Action

If CRA or Revenu Québec is auditing your GST/QST filings, or has frozen your refunds, contact Mackisen CPA immediately for complete audit defense.

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


Learning Conclusion:

A CRA GST/QST Audit tests every aspect of your sales tax compliance: invoices, payments, classifications, place-of-supply, and documentation quality.
Mackisen CPA Montreal ensures your file is clean, compliant, and defended — protecting your refunds, credits, and financial results.

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