How to File Taxes During a CRA Service Disruption (GST/QST Edition) — Montreal CPA Firm

A CRA service disruption — whether caused by system outages, strikes, cyber incidents, or maintenance — can create chaos for businesses trying to file GST or QST on time. Even if CRA systems are down, filing deadlines do not change, interest continues to accumulate, and penalties still apply. Many businesses assume that CRA will automatically grant relief during outages, but that is not guaranteed. Meanwhile, Revenue Québec may still require QST filings as scheduled, and missed filings can trigger refund freezes or compliance flags. This guide explains how to stay compliant during CRA disruptions using the emergency tax protocol Mackisen CPA Montreal uses for clients.

Why This Matters
GST/QST deadlines are fixed by law. Even when systems go down, CRA and RQ expect your returns to be filed and remitted by the due date. Failure to do so leads to:
Late filing penalties
Late payment interest
Refund holds
Potential compliance reviews
Audits triggered by missed periods
During disruptions, the burden is on the business to prove it attempted to file and remit correctly.

Legal and Regulatory Framework
Filing rules fall under:
The Excise Tax Act (GST/HST)
The Tax Administration Act (QST)
Both acts require timely filing regardless of technical issues.
Key jurisprudence:
Hickman Motors (1997, SCC) — taxpayers must maintain proper records and evidence
Canderel (1998, SCC) — filings must reflect commercial reality
Lac d’Amiante (2001, SCC) — RQ may reassess if filings are incomplete or late, regardless of external conditions

A business waits until the filing deadline to submit its GST return. On the final day, CRA’s portal suffers an outage. The business assumes CRA will offer leniency and files the next day. Weeks later, a Notice of Assessment arrives with penalties, interest, and a warning. CRA states they have “no record” of attempted filing on the due date. The business must now prove attempted compliance, but they have no screenshots, no email logs, and no proof. Their refund is delayed, and subsequent returns are flagged. All of this could have been avoided with proper disruption planning.

Learning Section: Understanding CRA Service Disruptions
Disruptions occur due to:
Scheduled maintenance
Unscheduled outages
Credential verification issues
Cybersecurity threats
CRA labour disputes
Overloaded servers near deadlines
In all cases, you must still demonstrate reasonable effort to file and remit taxes.

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How to File GST/QST During a CRA Service Disruption

Step 1: Take Screenshots of the Error
Before anything else, capture time-stamped evidence that CRA’s system is down:
Error page
Login failure
Submission failure
Service outage banner
Time and date visible
This protects you if CRA issues penalties.

Step 2: Attempt Filing Again Using Another Browser or Device
Try:
Chrome
Safari
Firefox
Edge
Try another computer or phone
This establishes reasonable effort.

Step 3: Use CRA’s Alternate Filing Methods
If My Business Account is down:
Use GST/HST NETFILE
Use GST/HST TELEFILE
Submit via approved third-party software
Even one successful alternate filing protects you from penalties.

Step 4: File QST Separately Through Revenue Québec
QST filing is not affected by CRA outages.
Log into Mon Dossier
File FPZ-500-V
Pay QST through online banking
Do not delay QST because CRA is down.

Step 5: Remit GST/QST Payment Even if Filing Isn’t Accepted Yet
Online banking payments still work even if CRA systems are down.
This protects you from interest.

Step 6: Keep All Evidence
Save:
Screenshots of errors
Email confirmation from CRA (if any)
Bank proof of payment
Timestamped attempts (browser history)
Mon Dossier QST filing confirmations
These documents protect you during disputes.

Step 7: Reattempt Filing Once Systems Return
When CRA is back online:
Submit the return
Attach any explanation (if requested)
Ensure the payment date matches deadline

Step 8: File a Penalty Relief Request if Needed
If CRA charges penalties due to the disruption, file:
Form RC4288 – Request for Taxpayer Relief
Attach all documentation proving attempted filing
Relief is often granted only when evidence exists.

Documentation Section
You must keep for six years:
Screenshots of CRA outages
GST/QST reconciliation reports
Bank payment confirmations
Email logs
Mon Dossier filing confirmations
CRA acknowledgements
Merchant processor reports
Invoices and proof of payment
These documents form your legal defense during a review.

Common Mistakes Businesses Make During CRA Disruptions
Waiting until the last minute to file
Failing to take screenshots
Not paying GST while filing is delayed
Thinking QST can be delayed because CRA is down
Assuming CRA will offer automatic relief
Not documenting attempts
Missing portal messages after service resumes
Not reconciling returns after disruption
These mistakes lead to penalties, denied relief, and refund holds.

Winning With Revenue Québec and Canada
Mackisen implements an emergency filing protocol for clients during outages. We:
Capture all system error evidence
Prepare alternative filing options
Ensure QST is filed on time
Submit GST/HST payments even if returns cannot be filed
Reconcile accounts after systems resume
Prepare penalty-relief requests if needed
Respond to CRA/RQ follow-ups
This ensures no client pays unnecessary penalties or interest.

Mackisen Service Hub
We provide:
Emergency GST/QST filing support
System outage compliance
Penalty-relief applications
GST/QST payment scheduling
Full reconciliation after disruption
Correspondence with CRA/RQ
Audit-proof documentation packages
We protect your compliance even when government systems fail.

Why Mackisen
With 35+ years of CPA experience, Mackisen CPA Montreal ensures your business stays compliant during CRA disruptions, QST filing cycles, and system outages. We safeguard your refunds, defend against penalties, and manage every step of the process — even when the government systems aren’t working.