Canada: Audit

Subscribe

Welcome to the Mondaq Audit Law homepage, here you will find thought leadership articles, podcasts, videos and webinars covering topics including accounting and audit law and insights.

CRA Uses ‘Alternative Methods’ For GST/HST Audits, Including Estimating Business Revenue, Reconstructing Missing Receipts

When the Canada Revenue Agency (CRA) concludes that a GST/HST registrant’s books and records do not provide a complete or reliable picture of its taxable sales, it may reconstruct those sales using an alternative or indirect audit method.

RS

Rotfleisch & Samulovitch P.C.

The Ultimate Guide To Offshore Reporting Requirements Of CRA’s Voluntary Disclosures Program (VDP)

Discovering previously unreported offshore assets or foreign income can instantly trigger significant financial and legal anxiety for Canadian taxpayers.

RS

Rotfleisch & Samulovitch P.C.

What Triggers A CRA Audit? Here’s The List, Compiled By A 40-year Canadian Tax Lawyer

The Canada Revenue Agency (CRA) employs a sophisticated, risk-based methodology to select taxpayers for a tax audit, ensuring compliance across the vast Canadian tax system.

RS

Rotfleisch & Samulovitch P.C.

How Section 296(2) Saves Expired GST/HST Input Tax Credits: Why The Ontario Tire Stewardship Case Is A Big Win For Businesses

The Tax Court of Canada’s May 7, 2026 decision in Ontario Tire Stewardship v The King, 2019-1330(GST)G, delivers a significant and taxpayer-favourable interpretation of subsection 296(2) of the Excise Tax Act (ETA).

RS

Rotfleisch & Samulovitch P.C.

The Complete Guide To Crypto-Asset Reporting Framework (CARF) For 2026-27 For Canadian Crypto Traders, Investors, And Accountants—and Enhanced Mandated Data Sharing Of Wallets With CRA

RS

Rotfleisch & Samulovitch P.C.

What Traders And Investors Need To Know About Cryptocurrency Tax Audits In Canada: CRA’s Tax Treatment, Audit Methods, Net-Worth Assessments, And Canadian Taxpayer Rights

RS

Rotfleisch & Samulovitch P.C.

Is It A Business Or A Hobby? What Triggers A CRA Tax Audit: Pursuit Of Profits, Expenses, Declared Losses

RS

Rotfleisch & Samulovitch P.C.

Why The Voluntary Disclosures Program (VDP) Is Better Than A CRA Tax Audit

Canada Government

RS

Rotfleisch & Samulovitch P.C.

Proactive CRA Objections Strategy: A Case Study On Controlling Process Risk And Protecting Taxpayer Rights

RS

Rotfleisch & Samulovitch P.C.

Canada Revenue Agency (“CRA”) Personal Services Business (“PSB”) Audits: What Incorporated Owner-operator Trucking Companies Need To Know

MT

Miller Thomson LLP

Accurate Record-Keeping For Tax Is The Responsibility Of Crypto Traders And Investors: Guidance From An Expert Canadian Tax Lawyer

RS

Rotfleisch & Samulovitch P.C.

Ignoring CRA Could Lead To Jail!

MK

Millar Kreklewetz

Data Privacy And Audit Evidence Challenges: If It’s Not Auditable, It’s Not Usable

Canada Accounting

PA

PKF Antares

Regulatory Risks Of Using AI In Financial Environments

Canada Technology

PA

PKF Antares

Remote Work As An Accommodation: What’s Reasonable In 2026?

Canada Employment

PH

Piccolo Heath

Crypto Tax Lawyer's Guide To DeFi, Yield Farming, & Liquidity In 2026

RS

Rotfleisch & Samulovitch P.C.

A Practical Guide For Business Owners Expanding Or Relocating To Ontario, Canada (Video)

Canada Commercial

LL

Lerners LLP

Supreme Court Of Canada Denies Leave In Wolastoqey Nation’s Aboriginal Title Claim

Canada Litigation

C

Cassels

Duty To Inquire About Disabilities: Key Lessons From A Recent Ontario Human Rights Decision

Canada Employment

F

Fasken

Why Tax Lawyers Have A Secret Weapon Against The CRA & Accountants Don’t: Solicitor-Client Privilege And The Limits Of CRA Audit Powers In Minister Of National Revenue v. KPMG Canada LLP

The Federal Court’s June 12, 2026 decision in Minister of National Revenue v KPMG Canada LLP, T-139-26, is a significant ruling on the limits of privilege assertions by third-party tax advisors in the context of CRA audits.

RS

Rotfleisch & Samulovitch P.C.

CRA Delays Under Formal Investigation: Limited Remedies For Taxpayers Facing Administrative Backlogs

Canada’s Taxpayers’ Ombudsperson has initiated a systemic examination into delays at the Canada Revenue Agency (CRA), focusing on prolonged processing timelines and deficiencies in complaint-resolution processes.

RS

Rotfleisch & Samulovitch P.C.

CRA vs. IRS Audits: What Every Canadian Tax Lawyer Wants You To Know

Cross-border taxpayers, corporations, investors, and high-net-worth individuals increasingly face scrutiny from both the Canada Revenue Agency (CRA) and the Internal Revenue Service (IRS).

RS

Rotfleisch & Samulovitch P.C.

Is The CRA Easier On You Than The IRS? A Canadian Tax Lawyer Explains Their Different Tactics, Processes

The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts.

RS

Rotfleisch & Samulovitch P.C.

CRA SR&ED Pre-Claim Approval Process (2026): Improved Strategic Tax Planning For SR&ED Tax Credits In Canada With Tax Credit Certainty, Faster Pro

RS

Rotfleisch & Samulovitch P.C.

Why Ontario Employer Health Tax (EHT) Assessment Disputes Frequently Escalate Into Tax Litigation: EHT Rules, Tax Audit Risk, And EHT Appeals

RS

Rotfleisch & Samulovitch P.C.

CRA Net Worth Audit Lawyer Canada: How Taxpage.com Successfully Argued Tax Court Of Canada Appeal, Reducing Client’s CRA Tax Reassessment By $400,000+ And Eliminating Gross Negligence Penalties

RS

Rotfleisch & Samulovitch P.C.

From 4% Random Selection To 100% Audit Risk: How CRA’S AI-Driven Audits Are Changing Tax Enforcement For Canadians

RS

Rotfleisch & Samulovitch P.C.

CRA Rejects Unreasonable Expenses For Commissioned Employees, Despite Having Filled Out Form T2200

RS

Rotfleisch & Samulovitch P.C.

Why Detailed Record-Keeping Is Critical To Deducting Business Expenses With CRA: A Canadian Tax Lawyer Analyzes Lessons Of Tax Court Case Bobic v. The King

RS

Rotfleisch & Samulovitch P.C.

Where AI Fits In The Audit Lifecycle: Reality vs Hype In AI Auditing

Canada Accounting

PA

PKF Antares

New CRA Commentary Provides Practical Clarity On The Voluntary Disclosures Program (VDP)

F

Fasken

When CRA Denies Business Losses: How To Respond, Protect Your Tax Deductions, And Win Your Tax Dispute

RS

Rotfleisch & Samulovitch P.C.

CRA Denied Your Business Loss After A Tax Audit? What To Do Immediately To Challenge The Reassessment

RS

Rotfleisch & Samulovitch P.C.

CRA vs. IRS Audits: What Every Canadian Tax Lawyer Wants You To Know

Cross-border taxpayers, corporations, investors, and high-net-worth individuals increasingly face scrutiny from both the Canada Revenue Agency (CRA) and the Internal Revenue Service (IRS).

RS

Rotfleisch & Samulovitch P.C.

Is The CRA Easier On You Than The IRS? A Canadian Tax Lawyer Explains Their Different Tactics, Processes

The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts.

RS

Rotfleisch & Samulovitch P.C.

CRA SR&ED Pre-Claim Approval Process (2026): Improved Strategic Tax Planning For SR&ED Tax Credits In Canada With Tax Credit Certainty, Faster Pro

The Scientific Research and Experimental Development (SR&ED) tax incentive program remains Canada’s most significant federal support mechanism for innovation, providing billions annually in SR&ED tax credits to businesses conducting qualifying research and development activities.

RS

Rotfleisch & Samulovitch P.C.

Why Ontario Employer Health Tax (EHT) Assessment Disputes Frequently Escalate Into Tax Litigation: EHT Rules, Tax Audit Risk, And EHT Appeals

Employer Health Tax Ontario (EHT) is a critical provincial payroll tax that continues to generate significant tax audit disputes and litigation risk for Ontario employers. As businesses grow, restructure, or adopt more complex payroll and corporate arrangements, exposure to an Employer Health Tax reassessment increases materially.

RS

Rotfleisch & Samulovitch P.C.

How To Be Audit Ready In The Face Of Canada’s New Transfer Pricing Rules

OH

Osler, Hoskin & Harcourt LLP

CRA SR&ED Pre-Claim Approval Process (2026): Improved Strategic Tax Planning For SR&ED Tax Credits In Canada With Tax Credit Certainty, Faster Pro

The Scientific Research and Experimental Development (SR&ED) tax incentive program remains Canada’s most significant federal support mechanism for innovation, providing billions annually in SR&ED tax credits to businesses conducting qualifying research and development activities.

RS

Rotfleisch & Samulovitch P.C.

Why Ontario Employer Health Tax (EHT) Assessment Disputes Frequently Escalate Into Tax Litigation: EHT Rules, Tax Audit Risk, And EHT Appeals

Employer Health Tax Ontario (EHT) is a critical provincial payroll tax that continues to generate significant tax audit disputes and litigation risk for Ontario employers. As businesses grow, restructure, or adopt more complex payroll and corporate arrangements, exposure to an Employer Health Tax reassessment increases materially.

RS

Rotfleisch & Samulovitch P.C.

CRA Real Estate Tax Audits Using MLS Data: Builder Risk, GST/HST Exposure & Audit Defence Strategies In Canada

CRA real estate tax audits have entered a new phase of sophistication, with the Agency increasingly relying on third-party data sources — most notably MLS listings — to identify potential non-compliance.

RS

Rotfleisch & Samulovitch P.C.

2251102 Ontario Inc. v. The King – CRA Net Worth Tax Reassessments Triggered By Taxpayer’s Bad Bookkeeping, Lack Of Receipts; CRA’s Reassessment Process Hard To Fight Against

In 2251102 Ontario Inc. v. The King, 2026 TCC 61, the Tax Court of Canada considered whether a taxpayer can successfully challenge a tax reassessment based on a net worth analysis where the CRA has relied on indirect methods due to inadequate books and records.

RS

Rotfleisch & Samulovitch P.C.

A Canadian Tax Audit Compared With A Criminal Investigation: Important Differences And Legal Protections For Taxpayers In Gravel v. Agence Du Revenu Du Québec

RS

Rotfleisch & Samulovitch P.C.

Proposed Expansion Of CRA Audit Powers: The Latest

BC

Blake, Cassels & Graydon LLP

The Transfer Pricing Audit: 2026 Transfer Pricing Guide – Part 2

MT

McCarthy Tétrault LLP

Voies De Recours Prévues Par Le Droit Domestique Pour L'Obtention D'Un Redressement : Guide Sur Le Prix De Transfert 2026 - Partie 3

MT

McCarthy Tétrault LLP

Fraud Risk, Governance And Accountability In First Nations: Why It Matters More Than Ever

Canada Criminal

MA

MLT Aikins LLP

Vérification De Prix De Transfert : Guide Sur Le Prix De Transfert 2026 - Partie 2

MT

McCarthy Tétrault LLP

Notice Of Objection Window | What Carries Forward

CT

Counter Tax Litigators

CRA Reassessment | What Happens Next

Canada Commercial

CT

Counter Tax Litigators

Don't Miss The Buzzer: Change Of Auditor Notice Requirements

BL

Borden Ladner Gervais LLP

CRA Trust Reporting Requirements In Canada: T3 Filing Rules, Bare Trust Updates & Tax Audit Risk

RS

Rotfleisch & Samulovitch P.C.

A Canadian Tax Audit Compared With A Criminal Investigation: Important Differences And Legal Protections For Taxpayers In Gravel v. Agence Du Revenu Du Québec

RS

Rotfleisch & Samulovitch P.C.

Navigating Indirect Tax Audits: Key Insights And Resolution Strategies

BC

Blake, Cassels & Graydon LLP

CRA Home "Builder" Audits Using MLS Data!

MK

Millar Kreklewetz

Audit Inquiries Require Careful Responses

Canada Accounting

MK

Millar Kreklewetz

Foreign Assets Under The Microscope: Navigating Today's T1135 Audit Push

BL

Borden Ladner Gervais LLP

See more

Highlighted Content

CRA Uses ‘Alternative Methods’ For GST/HST Audits, Including Estimating Business Revenue, Reconstructing Missing Receipts

RS

Rotfleisch & Samulovitch P.C.

The Ultimate Guide To Offshore Reporting Requirements Of CRA’s Voluntary Disclosures Program (VDP)

RS

Rotfleisch & Samulovitch P.C.

What Triggers A CRA Audit? Here’s The List, Compiled By A 40-year Canadian Tax Lawyer

RS

Rotfleisch & Samulovitch P.C.

How Section 296(2) Saves Expired GST/HST Input Tax Credits: Why The Ontario Tire Stewardship Case Is A Big Win For Businesses

RS

Rotfleisch & Samulovitch P.C.

The Complete Guide To Crypto-Asset Reporting Framework (CARF) For 2026-27 For Canadian Crypto Traders, Investors, And Accountants—and Enhanced Mandated Data Sharing Of Wallets With CRA

RS

Rotfleisch & Samulovitch P.C.

What Traders And Investors Need To Know About Cryptocurrency Tax Audits In Canada: CRA’s Tax Treatment, Audit Methods, Net-Worth Assessments, And Canadian Taxpayer Rights

RS

Rotfleisch & Samulovitch P.C.

Why Tax Lawyers Have A Secret Weapon Against The CRA & Accountants Don’t: Solicitor-Client Privilege And The Limits Of CRA Audit Powers In Minister Of National Revenue v. KPMG Canada LLP

RS

Rotfleisch & Samulovitch P.C.

CRA Delays Under Formal Investigation: Limited Remedies For Taxpayers Facing Administrative Backlogs

RS

Rotfleisch & Samulovitch P.C.

Is The CRA Easier On You Than The IRS? A Canadian Tax Lawyer Explains Their Different Tactics, Processes

RS

Rotfleisch & Samulovitch P.C.

CRA vs. IRS Audits: What Every Canadian Tax Lawyer Wants You To Know

RS

Rotfleisch & Samulovitch P.C.

Latest Videos

See more

Tax Litigation Video Series - What To Do When The CRA Calls (Video)

AB

Aird & Berlis LLP

Insider Threats: Identifying And Mitigating Risks From Within (Video)

CM

Crowe MacKay LLP

Our "Tax Take" On Canada's COVID-19 Economic Response Plan (Video)

MP

Moodys Private Client Law LLP

Accelerating Business | Episode 3 (Video)

GW

Gowling WLG

Nouveautés en droit fiscal : Soyez bien au fait (Video)

SE

Stikeman Elliott LLP

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More