How to File Taxes During a CRA Service Disruption (GST/QST Edition)

Introduction
When the Canada Revenue Agency (CRA) or Revenu Québec (ARQ) experiences a service disruption whether due to a strike, system outage, or scheduled maintenance business owners are still responsible for filing and remitting GST (Goods and Services Tax) and QST (Quebec Sales Tax) on time. These interruptions can create confusion about deadlines, payments, and penalties.

At Mackisen CPA Montreal, we help clients stay compliant even when government systems are down. With over 35 years of combined CPA and legal experience, our team ensures your filings, payments, and proof of compliance are properly documented during any CRA or ARQ service disruption. This guide explains how to file, remit, and protect your business during such events.

Legal and Regulatory Framework
Your filing obligation continues even if CRA or Revenu Québec systems are unavailable:

• Excise Tax Act (Canada) s.225 & s.228 — requires registrants to file GST/HST returns by their due dates.

• Taxation Act (Quebec) s.407 — requires QST returns to be submitted within prescribed filing periods.

• Tax Administration Act (Quebec) s.59(3) — authorizes interest on late payments unless the delay is justified by a documented system failure.

• CRA Policy P-148 and Revenu Québec Circular LAF.94-1 — allow penalty relief if delays were beyond the taxpayer’s control (e.g., service interruptions, natural disasters).

In other words, you’re still responsible for demonstrating due diligence—proof that you tried to file or pay on time.

Step-by-Step: How to File and Remit GST/QST During a Service Disruption

1. Check Official Announcements

   • Visit CRA’s System Status page (http://canada.ca/en/revenue-agency.html) and Revenu Québec’s Alerts section (http://revenuquebec.ca/).

   • Look for official confirmation of system outages or service interruptions. Save a PDF or screenshot of these notices—this serves as proof of disruption for future penalty relief requests.

2. Prepare Your Returns as Usual

   • Continue calculating GST and QST collected, Input Tax Credits (ITCs), and Input Tax Refunds (ITRs) using your accounting software.

   • Generate the filing reports as if you were submitting them online. Save a timestamped copy of each return.

3. Submit Through Alternative Channels

   • If CRA’s My Business Account is down, you can:

     • File by mail to your local CRA tax centre.

     • Submit payments via online banking (select “CRA GST/HST” as payee).

   • If Revenu Québec’s Mon Dossier is unavailable:

     • File through EDI (Electronic Data Interchange) or compatible accounting software.

     • Mail printed copies of your FPZ-500-V return.

4. Make Payments Electronically Even If Portals Are Down

   • CRA and ARQ bank payee systems often remain operational even during outages.

   • Use your online banking account to remit funds directly to “Receiver General for Canada (GST/HST)” or “Revenu Québec – QST/TVQ.”

   • Keep payment confirmations as proof.

5. Document Your Efforts to File

   • Save screenshots showing system errors or maintenance messages.

   • Retain emails from CRA or Revenu Québec acknowledging the disruption.

   • Record dates and times you attempted to access the system.

6. File As Soon As Service Resumes

   • Submit your GST and QST returns immediately once systems are restored.

   • Attach a cover note or include remarks in your submission referencing the outage.

7. Apply for Penalty Relief if Needed

   • If penalties or interest were applied despite timely efforts, request relief:

     • CRA: File Form RC4288 — Request for Taxpayer Relief.

     • Revenu Québec: File Form MR-93.1.1 — Request for Cancellation or Waiver of Interest or Penalties.

   • Attach your saved proof of outage, attempted submission, and payment confirmation.

Jurisprudence and Legal Insights
Canadian courts and administrative rulings confirm that the taxpayer’s duty is to act in good faith and maintain evidence of compliance efforts:

• Hickman Motors Ltd. v. Canada (SCC 1997) — CRA assessments are presumed correct unless the taxpayer presents credible proof.

• Royal Bank of Canada v. The Queen (FCA 2012) — technical failures do not excuse late filings without proof of diligence.

• Revenu Québec Administrative Policy (2019-01) — allows penalty cancellations for documented service outages, strikes, or force majeure events.

These cases demonstrate that maintaining documentation is the key to penalty relief.

Documentation: Building an Audit-Proof File
To protect yourself, create a Service Disruption Compliance File that includes:

• Screenshots of CRA/ARQ outage notices.

• Copies of GST and QST returns prepared during the disruption.

• Online banking or payment confirmation receipts.

• Logs of filing attempts (date, time, and outcome).

• Copies of all correspondence with CRA or Revenu Québec.

At Mackisen CPA Montreal, we prepare a complete Tax Compliance Binder for clients during system outages ensuring every proof of due diligence is properly archived.

How CRA and Revenu Québec Review Delay Claims
When reviewing penalty-relief applications, both agencies look for:

• Evidence of official outage announcements.

• Timestamped documentation showing you attempted to comply on time.

• Immediate filing once services resumed.

• Consistency between payment dates and filing records.

If satisfied, both CRA and ARQ will typically waive penalties and interest retroactively.

Winning With CRA and Revenu Québec
At Mackisen CPA Montreal, our process for protecting clients during CRA and Revenu Québec outages includes:

1. Proactive Monitoring – We track CRA/ARQ service updates and alert clients immediately.

2. Pre-Filing Preparation – We prepare returns in advance, ready to file the moment systems reopen.

3. Proof Collection – We document every attempt, outage notice, and transaction for legal defense.

4. Relief Applications – Our tax lawyers file requests under s.94.1 (TAA) or CRA Policy P-148 to cancel penalties.

5. Post-Outage Reconciliation – We confirm all filings are recorded and posted correctly.

Mackisen Service Hub: Compliance That Never Stops
Our Mackisen Service Hub protects your business continuity during any CRA or Revenu Québec service disruption. Services include:

• Real-time outage alerts and contingency filing.

• Pre-outage GST/QST filing preparation.

• Proof-of-compliance documentation and archiving.

• Audit defense and penalty relief filing.

• Bilingual representation with both agencies.

Our CPA auditors and tax lawyers graduates of McGill, Université de Montréal, and Concordia University work as one team to ensure your compliance is unbroken, even when government systems fail.

Real Client Example
During the 2024 CRA system maintenance shutdown, a Quebec-based consulting firm was unable to file its GST/QST returns online before the deadline. Mackisen CPA prepared manual filings, made payments through online banking, and documented CRA’s outage notices. When penalties were issued, we submitted a taxpayer relief request under Excise Tax Act s.280(1) and Tax Administration Act s.94.1. The penalties were fully waived, and the client received written acknowledgment of compliance.

Why Mackisen
With more than 35 years of combined CPA and legal experience, Mackisen CPA Montreal ensures your tax compliance continues uninterrupted even when CRA or Revenu Québec doesn’t. We help you file, pay, and defend your GST/QST returns with full documentation and legal protection.

When systems go down, Mackisen stands up for your business proving your diligence, protecting your rights, and keeping your compliance flawless.