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

A CRA Large-Case GST/HST Audit targets corporations with complex, high-value, or multi-jurisdictional transactions. These audits are not random — they are strategic reviews conducted by the CRA’s Large Business Audit Division for organizations whose annual revenues exceed $250 million or who engage in cross-border, intercompany, or industry-specific tax structures.
Mackisen CPA Montreal represents large corporations during these in-depth audits, ensuring every GST/HST transaction, intercompany charge, and input-tax-credit (ITC) claim meets the strict documentation and compliance standards required by the Excise Tax Act.

Legal Foundation

Law: Excise Tax Act (ETA) s. 231.1 — CRA’s audit powers; s. 286 — record-keeping; s. 169 — ITC eligibility; s. 225 — time limits for refunds and adjustments.
Jurisprudence: GlaxoSmithKline Inc. v. Canada (2012 SCC) — confirmed that tax authorities must consider commercial reality and arm’s-length pricing when auditing related-party transactions.

Learning insight: In a Large-Case audit, the CRA assumes complexity means opportunity — Mackisen CPA proves compliance through clarity.

Why CRA Targets Large-Case GST/HST Audits

The CRA’s Large Business Audit Program focuses on corporations where small rate errors equal large dollar exposures. Typical audit triggers include:

• Rapid growth or mergers creating complex supply chains.

• Significant GST/HST refunds or input-tax-credit balances.

• Intercompany service or royalty agreements spanning provinces or countries.

• Transactions involving exempt or zero-rated supplies.

• High-volume exports, imports, or digital-service platforms.

Learning insight: Large-case auditors don’t look for mistakes — they look for patterns. Mackisen CPA makes sure the only pattern they find is compliance.

What Mackisen CPA’s Large-Case Audit Defense Includes

1. Comprehensive Risk Mapping — Identify every high-risk transaction category before CRA does.

2. Transaction-Level ITC Reconciliation — Match every credit claimed to a valid invoice and payment record.

3. Intercompany Pricing Documentation — Align transfer-pricing policies with GST/HST valuation rules.

4. Place-of-Supply Verification — Ensure correct provincial rates are applied across interprovincial flows.

5. CRA Communication Management — Our partners liaise directly with Large Case Auditors to clarify issues before they escalate.

Learning insight: Complex audits are won in the first 30 days — documentation strategy determines outcome.

Common Exposure Areas in Large-Case Audits

• Unclaimed ITCs due to incomplete supplier information.

• Intercompany management fees lacking service detail.

• Incorrect application of zero-rated vs. exempt designations.

• Cross-border supplies without valid import/export proof.

• Improper tax treatment on royalties, licensing, or R&D services.

Mackisen CPA Montreal rebuilds every audit trail to ensure your GST/HST transactions meet the legal and evidentiary standard of ETA s. 286.

Learning insight: Every dollar CRA questions begins with a missing document — Mackisen CPA ensures none are missing.

How Mackisen CPA Manages Large-Case Audits

1. Conducts an internal audit mirroring CRA’s Large Business methodology.

2. Creates a digital documentation binder indexed to CRA request codes.

3. Prepares analytical summaries reconciling GST/HST payable, receivable, and revenue.

4. Represents your corporation in all CRA and Revenu Québec interviews.

5. Implements future-proof compliance systems post-audit.

Learning insight: CRA may audit your past, but Mackisen CPA protects your future by designing permanent controls.

The Financial Impact of Large-Case GST/HST Audits

Large-case audits can span 12–24 months and cover multiple tax years. A single reassessment can exceed $1 million when ITCs, penalties, and compound interest are combined.
Proactive management and professional representation can reduce both exposure and duration — saving months of cash-flow stress.

Learning insight: CRA measures compliance in evidence, not effort. Mackisen CPA turns effort into documented proof.

SEO Optimization and Learning Value

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Secondary Keywords: CRA audit representation, GST/HST ITC documentation, transfer-pricing audit support, excise tax law Canada, multinational audit defense.

Learning insight: Big audits don’t require fear — they require strategy. Mackisen CPA gives you both clarity and control.

Real Client Success

• A Québec manufacturer cleared $1.6 million in disputed ITCs after Mackisen CPA demonstrated valid intercompany documentation.

• A digital-media group reduced a $480 000 reassessment to $0 when we proved correct place-of-supply treatment.

• An import-export corporation saw its 14-month CRA audit close in 5 months after adopting our pre-audit documentation system.

Learning insight: In a Large-Case audit, speed comes from structure — Mackisen CPA builds it before CRA asks.

Why Mackisen CPA Montreal

With 35 years of audit and tax-law experience, Mackisen CPA Montreal serves as a full-service audit defense partner for corporations across Québec and Canada. Our bilingual CPAs and former CRA/ARQ officers understand how large-case auditors think — allowing us to anticipate every question before it’s asked.
From construction and manufacturing to digital and financial sectors, we protect corporate reputations, recover withheld refunds, and prevent multimillion-dollar reassessments.

Learning insight: A CRA Large-Case audit is not a test of size — it’s a test of systems. Mackisen CPA makes your systems audit-proof.