GST/HST Audit Support Case Studies

6 worked GST/HST Audit Support case studies — the position a client typically comes to us with, what we do, and what it is worth. Each is an illustrative example built on the rules that apply to gst/hst audit support work, not a specific client's file.

Case Study 1 · Planning that cut the bill

$26,500 Cut From The Annual Tax Bill — Mixed-Use Landlord, Barrie

Client: A residential landlord also renting commercial space  ·  Where: Barrie, Ontario  ·  Engagement: 11 weeks, fixed fee

First-year saving$26,500
RepeatsAnnually
Filing positionUnchanged in risk

The situation — A residential landlord also renting commercial space, Barrie, Ontario

A residential landlord also renting commercial space in Barrie, Ontario was compliant but paying more than it needed to. The prior year had been filed correctly. It still left input tax credits claimed on the exempt side of a mixed-supply business on the table.

What we did for A residential landlord also renting commercial space, Barrie, Ontario

We modelled the current position against the alternatives before changing anything. Then we set a defensible input tax credit allocation between taxable and exempt supplies and documented the method for future filings.

The result — A residential landlord also renting commercial space, Barrie, Ontario

The change saved $26,500 in the first year and repeats annually. Nothing about the filings became more aggressive. The position is simply the one the rules already allowed.

Case Study 2 · Objection and relief

Desk-Review Assessment Of $124,000 Vacated — Exempt-Supply Clinic, Kelowna

Client: A health clinic making exempt supplies  ·  Where: Kelowna, British Columbia  ·  Engagement: 9 weeks, fixed fee

Assessment vacated$124,000
Supporting recordsNow on file
AccountCleared

The situation — A health clinic making exempt supplies, Kelowna, British Columbia

A health clinic making exempt supplies in Kelowna, British Columbia was carrying $124,000 of penalties and interest. The charges arose from a sales tax account filed annually while the CRA had moved the business to quarterly. Much of that amount accumulated during a period the CRA itself had delayed.

What we did for A health clinic making exempt supplies, Kelowna, British Columbia

We brought the nil and missing periods current so the account was clean before the refund claim was filed. We framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.

The result — A health clinic making exempt supplies, Kelowna, British Columbia

The assessment was vacated. $124,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.

Case Study 3 · Missed incentive claimed

Incentive Review Recovered $102,000 Across 7 Open Years — Multi-Province Online Retailer, Guelph

Client: A multi-province online retailer  ·  Where: Guelph, Ontario  ·  Engagement: 11 weeks, fixed fee

Recovered$102,000
Open years claimed7
Ongoing trackingIn place

The situation — A multi-province online retailer, Guelph, Ontario

An incentive review at a multi-province online retailer in Guelph, Ontario started from a simple question: what has never been claimed? The answer ran to 7 years. It was driven by input tax credits claimed on the exempt side of a mixed-supply business.

What we did for A multi-province online retailer, Guelph, Ontario

We assembled the export documentation, restored zero-rating on the qualifying sales, and reduced the proposed assessment. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.

The result — A multi-province online retailer, Guelph, Ontario

The credits produced $102,000 across the open years. The tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.

Case Study 4 · Cash and remittance control

Instalments Rebased, $84,000 Of Cash Returned To The Business — Cross-Border SaaS Company, Lethbridge

Client: A SaaS company with Canadian and US customers  ·  Where: Lethbridge, Alberta  ·  Engagement: 5 weeks, fixed fee

Cash returned$84,000
Instalment basisCurrent year
ReviewedQuarterly

The situation — A SaaS company with Canadian and US customers, Lethbridge, Alberta

A SaaS company with Canadian and US customers in Lethbridge, Alberta was paying instalments calculated on a prior year. That year no longer reflected the business. HST charged at the home-province rate on sales into four different provinces was tying up $84,000 of cash.

What we did for A SaaS company with Canadian and US customers, Lethbridge, Alberta

We rebased the instalments on the current-year estimate rather than the prior-year default. Alongside that, we tested the quick method against the account’s actual input tax credit history and stayed on the regular method where the credits were worth more.

The result — A SaaS company with Canadian and US customers, Lethbridge, Alberta

$84,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.

Case Study 5 · Structure rebuilt

Holding Structure Added, $31,500 Saved Annually — Interprovincial Marketing Agency, Toronto

Client: A marketing agency billing outside its home province  ·  Where: Toronto, Ontario  ·  Engagement: 7 weeks, fixed fee

Annual saving$31,500
ReorganisationTax-neutral
StructureMatches operations

The situation — A marketing agency billing outside its home province, Toronto, Ontario

The structure at a marketing agency billing outside its home province in Toronto, Ontario needed fixing. The file was carrying export sales zero-rated with no shipping documentation behind them. Every option for fixing it ran through a reorganisation that had to be done without triggering tax.

What we did for A marketing agency billing outside its home province, Toronto, Ontario

We worked with the client's lawyer. Together, we filed the section 156 election for the related registrants, so supplies between them stopped carrying tax that served no purpose but cash-flow drag. We also prepared the elections, resolutions and valuations the structure needed to stand up.

The result — A marketing agency billing outside its home province, Toronto, Ontario

The structure now matches the business. Annual saving of $31,500, and the reorganisation itself was tax-neutral.

Case Study 6 · CRA review defended

$60,000 Proposed Adjustment Withdrawn In Full — Restaurant Group, Calgary

Client: A restaurant group  ·  Where: Calgary, Alberta  ·  Engagement: 4 weeks, fixed fee

Adjustment withdrawn$60,000
File closed in4 weeks
Penalties assessedNone

The situation — A restaurant group, Calgary, Alberta

A restaurant group in Calgary, Alberta received a proposal letter opening a review of GST/HST audit support. The CRA had identified management fees between two related registrants carrying tax that only ever went out and came back. It proposed an adjustment of $60,000, with 30 days to respond.

What we did for A restaurant group, Calgary, Alberta

We treated the response as an evidence exercise rather than an argument. We rebuilt the sales ledger by customer province and applied the correct place-of-supply rate to each stream. We filed corrected returns before the CRA opened a review. We then indexed every supporting document against the specific line the auditor had questioned.

The result — A restaurant group, Calgary, Alberta

The proposed adjustment was withdrawn in full — all $60,000 of it. The file closed in 4 weeks with no change to the assessed amounts and no penalty.

Reviewed by Udit Gupta, Founder and Tax Accountant for the 2025 tax year. These case studies are illustrative worked examples composed from the CRA rules that apply to this type of work, not specific client files; figures are representative and outcomes depend on your own facts.

Sources. CRA — GST/HST for businesses · CRA — GST/HST rates by province · Income Tax Act (Justice Laws Website)

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