CRA Large-Case GST/HST Audit — Montreal CPA Firm Near You: Complex Transactions, Intercompany Flows, and Multi-Province Tax Defense

A CRA Large-Case GST/HST Audit is the most advanced level of indirect-tax review conducted by the Canada Revenue Agency. These audits target corporations with complex supply chains, multi-jurisdictional sales, intercompany transactions, large refund claims, or high-risk industry patterns.
Mackisen CPA Montreal specializes in defending large, multi-entity, multi-province, and cross-border GST/HST files by building complete CPA-certified audit binders, reconstructing ITC claims, validating place-of-supply rules, and preparing legal-quality tax analysis that satisfies CRA’s Large Business Audit Division.

In a large-case audit, CRA brings senior auditors, economists, and industry specialists. Your defense must be equally structured, technical, and strategic.

Legal Foundation

Excise Tax Act ss.165–169 — governs GST/HST payable, collectible, and ITC eligibility.
Excise Tax Act s.286 — requires taxpayers to maintain complete books and records for six years.
Excise Tax Act s.288 — grants CRA the power to inspect premises, servers, POS systems, and electronic records.
Jurisprudence: Northwest Company Inc. (2011 TCC) — ITCs are denied if documentation does not meet statutory requirements, even if transactions are legitimate.

Learning insight: Large-case GST/HST audits are not about math — they are about evidence, structure, and tax logic.

Why CRA Initiates Large-Case GST/HST Audits

CRA’s Large Business Directorate selects files based on national risk indicators such as:
• multi-province operations with mixed GST/HST rates
• large or recurring refund claims
• complex intercompany service charges or cost-sharing
• foreign suppliers, digital services, or cross-border flows
• construction, manufacturing, logistics, retail, or wholesale sectors
• irregular ITC patterns compared to industry benchmarks
• high volume of subcontractors (often in construction and trucking)
• import/self-assessment inconsistencies

Learning insight: CRA assumes complexity increases audit risk. Your CPA must prove that complexity is documented compliance, not exposure.

CRA Large-Case Audit Process

1. CRA issues a detailed audit notice outlining scope, tax periods, and required documentation.

2. CRA holds an opening meeting with the corporation’s CFO or CPA.

3. CRA performs ITC sampling, supplier verification, payment tracing, and contract reviews.

4. CRA evaluates place-of-supply rules, especially for multi-province and export transactions.

5. CRA audits intercompany charges, management fees, and shared-service allocations.

6. CRA may expand scope to GST/HST on imports, drop-shipments, and digital supplies.

7. CRA issues a Proposed Audit Adjustment Letter (PAAL).

8. Mackisen CPA prepares rebuttals, tax memos, and documentation to challenge CRA assumptions.

Learning insight: Large-case audits are not won by responding — they are won by anticipating CRA’s next question.

Mackisen CPA’s Large-Case GST/HST Defense Strategy

• verify every supplier’s GST/HST/QST registration number
• validate all invoices for ETA s.169(4) documentation compliance
• prepare place-of-supply analysis for each province and service type
• reconcile ITC claims to bank payments, credit-card proofs, or EFTs
• document intercompany transactions with contracts, transfer-pricing memos, and cost-allocation schedules
• prepare CPA-certified ITC binders organized exactly in CRA’s preferred format
• provide economic and operational explanations for margins, refunds, and variances
• negotiate with CRA on technical matters (zero-rating, self-assessment, multi-province nexus)

Learning insight: CRA trusts files that look like their own internal templates. Mackisen CPA builds files that CRA can review — fast.

Common CRA Findings in Large-Case GST/HST Audits

• ITCs denied due to missing or incomplete invoices
• incorrect GST/HST rate applied to interprovincial supplies
• misclassification of taxable, exempt, and zero-rated supplies
• invalid subcontractor invoices or unregistered GST suppliers
• errors in GST self-assessment on imported services
• ITCs claimed by holding companies without clear commercial activity
• double claims for refunds or partial-period overlap
• drop-shipment or fulfillment-center errors for e-commerce
• foreign-supplier payments lacking documentation for ITC eligibility

Learning insight: The number one cause of reassessments is documentation failure, not tax miscalculation.

Real-World Results

• A national distributor recovered $1.3M in frozen GST/HST refunds after Mackisen CPA built a complete place-of-supply matrix and ITC binder that matched CRA’s audit protocol.
• A construction conglomerate avoided a $740,000 reassessment when we verified subcontractor registration and rebuilt missing invoice trails.
• A technology firm overturned CRA’s proposed adjustments to digital-service GST rules using ETA Schedule IX and CRA Policy P-051R2 analysis.
• A transportation company prevented a $520,000 GST/HST adjustment when we demonstrated correct zero-rating under export-service rules.

Learning insight: CRA reverses reassessments when the taxpayer’s documentation is stronger than the auditor’s assumptions.

SEO Optimization and Educational Value

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Learning insight: Large-case audits reward clarity. SEO also rewards clarity. Structured information wins in both arenas.

Why Mackisen CPA Montreal

Mackisen CPA Montreal has over 35 years of experience defending corporations against CRA and Revenu Québec sales-tax audits. Our bilingual team reconstructs ITCs, analyzes supply chains, and prepares legal-level tax documentation that satisfies even the most experienced CRA auditors.

Learning insight: Large-case audits are a test of your systems. We make sure your systems — and your documentation — pass every test.

Call to Action

If CRA or Revenu Québec has initiated a Large-Case GST/HST audit or requested complex documentation, act immediately.
Contact Mackisen CPA Montreal for expert representation, reconciliation, and audit-proof documentation.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com

Learning conclusion: A CRA Large-Case GST/HST Audit tests your processes, paperwork, and tax logic. Mackisen CPA Montreal ensures all three are defendable — turning CRA’s most challenging audit into a structured, controlled, and successful defense.