CRA Large-Case GST/HST Audit — Montreal CPA Firm Near You: Complex Transactions

A CRA Large-Case GST/HST Audit focuses on businesses with complex, high-value, or multi-jurisdictional transactions. These audits are typically assigned to CRA’s Large Business Audit Division and target corporations with annual revenues over $250 million, multinational operations, or recurring refund claims exceeding industry norms. Mackisen CPA Montreal provides professional audit defense, documentation, and coordination with both CRA and Revenue Québec to ensure full compliance and minimize exposure.

Legal Foundation

Law: Excise Tax Act s.288 (inspection and demand for information); s.289 (audit powers).
Jurisprudence: CRA Large-Case Audit Manual (2022) — established that large-case taxpayers must maintain contemporaneous transaction documentation for all intercompany and cross-border supplies.

Why You Need a CPA for a Large-Case GST/HST Audit

Large-business audits are intensive, detailed, and often prolonged, involving multiple departments and CRA audit specialists. CRA reviews corporate group structures, intercompany flows, transfer-pricing adjustments, and GST/HST recovery positions simultaneously. Mackisen CPA Montreal ensures all related-party transactions, ITC claims, and cross-border tax obligations are reconciled and defendable.

Learning insight: Large-case audits don’t test math—they test method. A CPA ensures your accounting method aligns with legal intent.

What Mackisen CPA’s Large-Case Audit Defense Includes

• Comprehensive mapping of supply chains, intercompany transactions, and tax flows.

• Validation of GST/HST registration and collection across divisions and subsidiaries.

• Review of place-of-supply rules for cross-border and interprovincial operations.

• Preparation of contemporaneous documentation under OECD and CRA standards.

• Coordination with legal counsel on tax-litigation risk areas.

Learning insight: CRA expects large taxpayers to operate like regulators. CPA oversight makes you one step ahead of them.

Common Triggers for CRA Large-Case Audits

• Recurring multi-million-dollar refund claims.

• High volume of cross-border or intercompany transfers.

• Large capital projects involving mixed taxable/exempt use.

• Discrepancies between income tax and GST/HST reporting.

• Third-party leads or inconsistencies in public filings.

Mackisen CPA Montreal identifies and mitigates these triggers through proactive documentation and internal compliance audits.

How Mackisen CPA Manages Large-Case GST/HST Audits

1. Conducts enterprise-wide GST/HST data reconciliation across multiple entities.

2. Reviews all major contracts for place-of-supply accuracy.

3. Validates ITC/ITR eligibility for shared or joint operations.

4. Coordinates communication with CRA’s Large Business Audit Division.

5. Files detailed CPA-certified audit binders for review and defense.

Learning insight: CRA uses algorithms to detect anomalies. A CPA replaces anomalies with alignment.

Benefits of Professional Representation

• Prevents large-scale reassessments through pre-emptive reconciliation.

• Minimizes operational disruption with centralized CRA coordination.

• Protects cash flow through accelerated refund-release support.

• Ensures compliance with both federal and provincial large-business requirements.

• Reduces exposure to interest and penalties under ETA s.285.

Learning insight: For large entities, GST/HST is not a tax—it’s a system. Mackisen CPA ensures the system runs without audit friction.

SEO Optimization and Learning Value

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Secondary Keywords: CRA cross-border GST audit, Mackisen corporate tax compliance, GST/HST enterprise audit defense, intercompany transaction review Montreal.

Learning insight: CRA evaluates processes, not people. Mackisen CPA designs processes that pass every audit test.

Real Client Success

• A multinational importer passed CRA’s Large-Case Audit after Mackisen CPA reconstructed three years of GST/HST intercompany reconciliations.

• A Quebec-based manufacturer prevented $2.1 million in denied ITCs by demonstrating eligible use of equipment purchases.

• A technology firm reduced its audit scope by 60% when our team pre-validated all cross-border service transactions.

Why Mackisen CPA Montreal

Mackisen CPA Montreal specializes in high-stakes corporate audits where precision and documentation define outcomes. Our firm’s combined legal, accounting, and audit expertise ensures every report withstands CRA scrutiny.

Learning insight: In a large-case audit, CRA assumes error until proven otherwise. Mackisen CPA provides the proof—before the assumption becomes an assessment.

Learning conclusion: CRA Large-Case Audits challenge systems, not spreadsheets. Mackisen CPA Montreal ensures your corporate systems are audit-proof, transparent, and strategically defended.