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

A CRA Large-Case GST/HST Audit targets corporations with complex financial structures, multiple entities, or high-value transactions across provinces and countries. These audits are led by CRA’s Large Business Audit Division and require precise documentation of intercompany supplies, Input Tax Credits (ITCs), and place-of-supply rules.
Mackisen CPA Montreal provides professional representation and documentation management to defend corporations during large-case audits, ensuring compliance under the Excise Tax Act while minimizing exposure, penalties, and business disruption.

Legal Foundation

Law: Excise Tax Act ss.165–169 (ITC entitlement and liability), s.286 (books and records), and s.288 (audit powers).
Jurisprudence: GlaxoSmithKline Inc. v. Canada (2012 SCC) — transactions must reflect commercial reality, not artificial arrangements, when determining GST/HST value and eligibility.

Learning insight: CRA doesn’t audit size — it audits systems. Mackisen CPA ensures your systems prove compliance, control, and credibility.

Why CRA Conducts Large-Case Audits

CRA audits large corporations when transactional complexity increases audit risk. Common reasons include:

• High-volume intercompany transactions.

• Frequent GST/HST refunds or adjustments.

• Cross-border or interprovincial supply of goods and services.

• Mergers, acquisitions, or reorganizations with tax implications.

• ITC claims on shared services or holding-company expenses.

Learning insight: CRA assumes complexity equals exposure. Mackisen CPA turns that complexity into structured, documented compliance.

CRA’s Large-Case Audit Process

1. Audit Initiation: CRA assigns a Large Business Audit Team and sends a formal notice.

2. Information Requests (RFI): CRA demands ledgers, contracts, invoices, and intercompany agreements.

3. Testing Phase: Auditors test ITCs, rate applications, and place-of-supply determinations.

4. Cross-Entity Verification: CRA reviews intercompany reconciliations for accuracy.

5. Proposed Adjustments: CRA issues preliminary findings for discussion and response.

6. Resolution: Mackisen CPA negotiates clarifications or corrections before final reassessment.

Learning insight: CRA reviews data, not discretion — but with Mackisen CPA, your documentation tells a consistent, defensible story.

Mackisen CPA’s Large-Case Audit Defense Framework

1. System Audit Preparation: Conduct internal reviews mirroring CRA’s methodology.

2. ITC Validation: Confirm supplier registration, invoice compliance, and business-purpose linkage.

3. Intercompany Reconciliation: Align GST/HST collected and remitted across subsidiaries.

4. Place-of-Supply Review: Apply CRA Memoranda 3.3 and 3.4 for cross-provincial rate consistency.

5. Documentation Binder: Prepare CPA-certified binders indexed to CRA audit requests.

6. Direct Representation: Handle all communications with CRA to maintain accuracy and efficiency.

Learning insight: CRA appreciates clarity — Mackisen CPA delivers documentation organized exactly to their audit standards.

Common CRA Findings in Large-Case GST/HST Audits

• ITCs claimed on holding-company or head-office expenses without clear taxable link.

• Intercompany management fees or shared-service charges lacking documentation.

• Incorrect HST rates applied on interprovincial services.

• GST/HST refunds unsupported by supplier proof or zero-rating documentation.

• Discrepancies between corporate divisions’ returns.

Mackisen CPA identifies these weaknesses early and structures responses backed by ETA, CRA memoranda, and jurisprudence.

Learning insight: CRA disallows unlinked ITCs — Mackisen CPA builds the link between every cost and its taxable activity.

Real-World Success

• A manufacturing group avoided a $1.8M reassessment after Mackisen CPA proved GST/HST compliance for intercompany service agreements.

• A logistics company cleared its large-case audit when we provided export and rate verification under ETA Schedule VI.

• A multi-entity real-estate group reduced a $540,000 adjustment by documenting holding-company costs as commercial activities.

Learning insight: CRA values thoroughness. Mackisen CPA turns every file into a detailed proof of compliance.

SEO Optimization and Learning Value

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Secondary Keywords: CRA ITC validation, intercompany GST audit, CRA cross-border compliance, Mackisen CPA Montreal defense, large corporate GST refund audit.

Learning insight: Both CRA and Google reward transparency and authority — Mackisen CPA delivers both through documentation and education.

Why Mackisen CPA Montreal

With 35 years of combined corporate audit and tax-law experience, Mackisen CPA Montreal is a trusted partner for large corporations across Québec and Canada. Our bilingual CPAs and tax specialists manage end-to-end CRA audits — from ITC defense to intercompany documentation — ensuring every transaction meets both the spirit and letter of the law.

Learning insight: CRA measures control; Mackisen CPA demonstrates mastery. We turn audits into evidence of excellence.

Call to Action

If CRA has initiated a Large-Case GST/HST Audit or requested intercompany documentation, act immediately.
Contact Mackisen CPA Montreal today for professional representation and full audit management.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com

Learning conclusion: CRA Large-Case Audits test organization and transparency. Mackisen CPA Montreal ensures your corporate systems and records pass that test — proving compliance, protecting credibility, and preventing costly reassessments.