How to Read Your GST/QST Notice of Assessment

Introduction
Receiving a Notice of Assessment (NOA) from the Canada Revenue Agency (CRA) or Revenu Québec (ARQ) can be stressful—especially if you don’t fully understand what it means. Yet, this document is one of the most important communications your business will ever receive. It tells you whether your GST/QST return has been accepted as filed, adjusted, or reassessed, and what your next steps should be.

At Mackisen CPA Montreal, we help business owners interpret, verify, and respond to every line of their GST/QST assessment. With over 35 years of combined CPA and legal experience, our auditors, accountants, and tax lawyers guide you through the process—protecting your rights, minimizing penalties, and keeping your business audit-ready.

Legal and Regulatory Framework
Every GST or QST Notice of Assessment is issued under federal and provincial legislation.

• Excise Tax Act (s. 296 and s. 297) authorizes the CRA to assess or reassess any GST return if it believes an error, omission, or underreporting has occurred.

• Tax Administration Act (s. 93) grants Revenu Québec similar powers to review and adjust QST filings within four years of the filing date.

• Income Tax Act (s. 152) establishes that once an assessment is issued, it is presumed correct unless the taxpayer provides evidence to the contrary.

These provisions mean the burden of proof lies with you, not the tax authorities. Understanding how to read your GST/QST Notice of Assessment is the first step in protecting yourself from errors, double taxation, or unnecessary penalties.

What a GST/QST Notice of Assessment Includes
When you receive your NOA—whether through CRA’s My Business Account or Revenu Québec’s Mon Dossier—it typically contains:

1. Reference Number and Period Assessed
   Identifies the reporting period covered (monthly, quarterly, or annual). Always verify that the period matches the return you filed.

2. Tax Calculations
   Displays the CRA or ARQ’s calculation of:

   • Total GST/QST collected

   • Input Tax Credits (ITCs) and Input Tax Refunds (ITRs)

   • Net tax owing or refundable

3. Adjustments or Corrections
   Lists changes made by the authority, such as disallowed ITCs/ITRs or adjustments for unreported sales.

4. Interest and Penalties
   Shows interest calculated under Excise Tax Act s. 280(1) or Tax Administration Act s. 59, compounded daily from the due date.

5. Payment Due or Refund Owing
   Indicates the final balance you must pay or will receive. Refunds may be delayed if the file is under review.

Jurisprudence and Audit Implications
Court rulings have consistently emphasized the importance of understanding and contesting GST/QST assessments promptly.

• Hickman Motors Ltd. v. Canada (SCC 1997) confirmed that CRA assessments carry a presumption of correctness—the taxpayer must disprove them.

• Lac d’Amiante du Québec Ltée (SCC 2001) upheld Revenu Québec’s right to inspect and reassess based on incomplete or inaccurate returns.

• Canderel Ltd. v. Canada (SCC 1998) established that reported figures must reflect commercial reality and be supported by valid documentation.

These precedents show that quick and accurate responses to your NOA are crucial. A misunderstanding or delay could allow an incorrect assessment to become final and enforceable.

Documentation: Verifying and Responding to an Assessment
When you receive your Notice of Assessment, follow these steps immediately:

1. Compare With Your Filed Return
   Match each line of the assessment to your submitted return. If there’s a discrepancy, identify whether it’s due to a late filing, missing receipt, or data entry error.

2. Review Supporting Documents
   Revenu Québec and CRA verify input tax credits and refunds based on documentation. Ensure every expense, sale, and adjustment is backed by an invoice or receipt showing GST/QST registration numbers.

3. Contact CRA or Revenu Québec Professionally
   If you believe the assessment is incorrect, contact the assigned officer or business inquiries line promptly. Always remain polite, factual, and organized—professionalism can influence how your case is handled.

4. File a Notice of Objection (If Needed)
   You have 90 days from the mailing date of the NOA to object under Income Tax Act s.165(1) or Tax Administration Act s.93.1. Missing this deadline can permanently forfeit your right to appeal.

At Mackisen CPA Montreal, our experts prepare your response and handle all correspondence with the authorities. Our documentation team reconstructs missing files, organizes evidence, and ensures that your objection is legally sound and audit-proof.

How CRA and Revenu Québec Conduct Reassessments
Both agencies use data-matching systems to detect inconsistencies between your filed returns and third-party records such as merchant processors, payroll data, and supplier filings.

If discrepancies are found, the typical process is:

1. Request for Information Letter – Asking for copies of invoices or proof of ITCs/ITRs.

2. Pre-Assessment Review – An internal verification of your records before reassessment.

3. Notice of Reassessment – If errors remain unresolved, a new NOA replaces the original.

Reassessments can include backdated interest and penalties covering multiple years. That’s why accurate filing and prompt review of your NOA are essential.

Winning With CRA and Revenu Québec
At Mackisen CPA Montreal, we’ve built our reputation on helping businesses resolve assessment disputes quickly and efficiently. Our 35+ years of combined experience allow us to turn reassessments into settlements and objections into approvals.

Our Proven Strategy to Win or Settle

1. Case Analysis – We dissect every line of the assessment, identifying calculation or documentation errors.

2. Evidence Reconstruction – Our accountants rebuild missing or incomplete proof to defend disallowed ITCs/ITRs.

3. Professional Representation – Our tax lawyers communicate directly with CRA and Revenu Québec officers on your behalf.

4. Negotiation and Resolution – We request reductions in penalties and interest under Tax Administration Act s.94.1 and CRA Policy P-148.

5. Final Victory – We secure written confirmation of adjustments, ensuring your record is cleared and your future filings are accurate.

Our philosophy is not to fight the system—but to understand it better than anyone else.

Mackisen Service Hub: Your Partner in Tax Defense
The Mackisen Service Hub is Montreal’s comprehensive compliance and audit support center. Our team includes:

• CPA Auditors who verify financial data before submission.

• Tax Lawyers experienced in GST/QST reassessments and appeals.

• Bookkeeping Experts who organize your documentation to prevent future disputes.

Every member of our team is a graduate of McGill University, Université de Montréal, or Concordia University, bringing decades of combined expertise in Canadian tax law and audit representation.

We don’t just explain your assessment—we make sure you understand every number, every right, and every next step.

Real Client Example
A Montreal retailer received a $78,000 reassessment after CRA disallowed input tax credits due to “missing invoices.” Mackisen CPA reconstructed three years of documentation, provided digital proof from suppliers, and filed a Notice of Objection under Income Tax Act s.165(1). Within eight weeks, CRA reversed the reassessment and approved a $14,000 refund.

Why Mackisen
With over 35 years of combined CPA and legal experience, Mackisen CPA Montreal remains one of Quebec’s most trusted authorities in GST/QST assessments and audit representation.

When you receive a Notice of Assessment, don’t face it alone. Our team of CPA auditors, tax lawyers, and compliance specialists will ensure that your file is defended with precision, professionalism, and full legal support.