Insight
Nov 24, 2025
Mackisen

CRA Worker Classification Audit — Montreal CPA Firm Near You: Employee vs. Contractor Defense

A CRA Worker Classification Audit is one of the most frequent and financially significant reviews conducted on small and medium businesses. It determines whether a worker should be classified as an employee (subject to payroll source deductions) or an independent contractor (self-employed). Mackisen CPA Montreal represents employers and contractors during these audits to prevent reclassification, penalties, and backdated CPP/EI contributions.
Worker classification affects every part of business compliance — payroll, remittances, GST/QST registration, employment standards, and liability insurance. A single misclassified relationship can cost tens of thousands in reassessments, interest, and penalties.
Legal Foundation
Law: Income Tax Act s.5 and s.9 — defines employment and business income.
Employment Insurance Act s.2 and s.5 — outlines who qualifies as an employee.
Tax Administration Act (Québec) s.40–44 — extends personal liability for unremitted payroll deductions.
Jurisprudence: Wiebe Door Services Ltd. v. M.N.R. (1986 FCA) — established the four-factor test for determining employee versus independent-contractor status: control, ownership of tools, chance of profit, and risk of loss.
Learning insight: CRA doesn’t judge based on title — it judges based on behaviour. Mackisen CPA ensures your contracts and practices tell the same legal story.
Why CRA and Revenu Québec Conduct Worker Classification Audits
These audits are triggered when:
T4A slips are issued instead of T4s for long-term workers.
CPP or EI contributions are missing or underpaid.
GST/QST registration numbers are inconsistent with earnings.
A former worker files for EI benefits after a contract ends.
CRA data matching identifies a high contractor-to-payroll ratio.
Learning insight: Worker misclassification isn’t about avoidance — it’s about alignment. Mackisen CPA aligns your evidence with the law, not assumptions.
CRA Worker Classification Audit Process
Audit Notice: CRA contacts employer requesting contracts and payment records.
Relationship Review: Auditors interview management and workers to evaluate the four Wiebe Door factors.
Legal Test Application: CRA decides if the worker is economically dependent on the payer.
Reassessment or Clearance: CRA either confirms contractor status or issues a reassessment for CPP/EI, income tax, and penalties.
Appeal: Mackisen CPA prepares a detailed written objection referencing jurisprudence and factual evidence.
Learning insight: The test isn’t about labels — it’s about facts. CRA examines who holds risk, not who signs the invoice.
What Mackisen CPA’s Worker Classification Audit Defense Includes
Legal review of employment and service contracts.
Control, integration, and risk analysis based on Wiebe Door principles.
Documentation proving business independence (invoices, insurance, advertising).
CPP/EI recalculation to mitigate penalties if reclassification occurs.
Full representation during CRA and Revenu Québec interviews and appeals.
Learning insight: The CRA looks backward five years — Mackisen CPA builds forward compliance that lasts.
Common CRA and ARQ Audit Red Flags
Contractor uses company equipment or works full-time hours.
Contractor has no business number, GST/QST registration, or other clients.
Payer reimburses expenses without invoices.
Payments are weekly or bi-weekly like salaries.
Worker uses payer’s email domain or business card.
Mackisen CPA pre-emptively identifies these high-risk situations and restructures them into legitimate independent business relationships.
Real-World Results
A construction company avoided $240,000 in payroll reassessments after Mackisen CPA demonstrated subcontractor independence using Wiebe Door criteria.
A Québec technology firm preserved contractor relationships after we updated agreements and added proof of business risk and insurance.
A professional-services client obtained full EI appeal reversal when Mackisen CPA proved shared control and entrepreneurial intent.
Learning insight: Independence is proven through paperwork, not personality. Mackisen CPA ensures your contracts defend your classification.
SEO Optimization and Educational Value
Primary Keywords: CRA Worker Classification Audit, Employee vs Contractor, Mackisen CPA Montreal, CPP EI Payroll Audit, CPA Firm Near You, CRA Independent Contractor Rules.
Secondary Keywords: CRA contractor test, Wiebe Door four-factor test, CPP EI reassessment defense, CRA payroll compliance, Mackisen CPA classification audit.
Learning insight: Google favors expertise — just like CRA. Educating your audience builds both compliance and authority.
Why Mackisen CPA Montreal
With 35+ years of CPA experience, Mackisen CPA Montreal is trusted for complex worker-classification defense across industries — construction, consulting, IT, creative, and healthcare. We combine tax law, employment law, and audit expertise to protect employers from reassessment and safeguard contractors’ business independence.
Learning insight: Worker classification isn’t about what you call them — it’s about what you prove. Mackisen CPA makes that proof bulletproof.
Call to Action
If CRA or Revenu Québec has contacted you about contractor status or payroll remittances, don’t wait.
Call Mackisen CPA Montreal today for a full worker-classification analysis and audit defense strategy.
Phone: 514-276-0808 | Email: info@mackisen.com | Website: mackisen.com
Learning conclusion: The difference between a job and a contract is paperwork — and paperwork is what CRA audits. Mackisen CPA Montreal ensures your classification passes every legal and financial test.

