ITCs Denied or Sales Reassessed? Build the Evidence that Moves CRA

We turn your HST reassessment into a clear, documented case—so you can protect cash flow and get back to business in Toronto & surrounding areas

If you’ve received an HST Reassessment (often called a Notice of Reassessment), you’re likely juggling three questions at once: why it happened, what to do first, and how to prevent it from disrupting cash flow. This page lays out a practical plan for Toronto business owners—how we dissect the reassessment, when a Notice of Objection makes sense, and how our team at Misir & Company manages the process end to end.

Who this is for

• Corporations and sole proprietors registered for GST/HST in Toronto & surrounding areas

• Businesses dealing with denied Input Tax Credits (ITCs), unreported supplies, coding mistakes, or missing documentation

• Owners who need a calm, step-by-step way to respond while keeping the business running

First things first: your steady plan within 24–72 hours

When HST is reassessed, time, documentation, and messaging matter. Our approach focuses on speed without sacrificing quality:

1. Timeline check & protective steps

   We confirm the reassessment date, any 90-day objection window, and the collection status. If deadlines are tight, we file protective paperwork and then supplement with a full brief.
   

2. Evidence triage

   We review returns, invoices, purchase records, bank statements, merchant reports, and accounting files to see what CRA saw and what they didn’t. You get a prioritized list of documents to gather—no guesswork.
   

3. Position mapping

   We outline the issues, facts, and law/policy that support your position, and we show how each exhibit proves a point. Clear mapping helps an Appeals Officer connect the dots.
   

4. Communication plan

   We handle CRA communications, track milestones, and keep you updated with concise status notes. If collections activity is active, we discuss practical cash-flow options while the dispute continues.

Why HST gets reassessed—and how we fix the root causes

HST reassessment usually points to a gap between your records and CRA’s expectations. We address both the immediate dispute and the systems that caused it.

Common triggers we resolve

• Denied ITCs due to invoice defects (missing supplier info, GST/HST numbers, or insufficient detail)

• Coding errors (zero-rated vs. exempt supplies, place-of-supply mistakes, mixed-use purchases)

• Unreported or misclassified revenue flagged by bank deposits, payment processors, or POS analytics

• Registration threshold issues for sole proprietors crossing the small-supplier limit

• Subcontractor vs. employee characterization affecting ITCs and payroll interfaces

• Record-keeping gaps—documents exist but aren’t organized to CRA’s standards
  

Our fix-forward philosophy

• Document once, use many times. Each exhibit is indexed and cross-referenced; you can re-use the package for lenders, insurers, or future audits.

• Plain-language summaries. We translate accounting details into clear narratives that answer: What changed? Why is your position correct?

• Process upgrades. We suggest practical controls (invoice templates, coding rules, reconciliations) that reduce the risk of another reassessment.

What to do if you get a Notice of Reassessment (checklist)

Right now (Day 0–7)

• Save the Notice of Reassessment and any audit letters.

• Export GST/HST returns, ITC schedules, and the general ledger for the periods in question.

• Pull source documents: invoices, receipts, contracts, bank statements, credit-card summaries, and POS reports.

• Capture a short timeline: when you received the notice, when CRA contacted you, and what was requested.

• Book a call with our team to confirm deadlines and collections status.
  

Soon after (Week 1–3)

• We identify the issues list and collect missing support.

• We draft your position letter and build the evidence index (exhibit tabs, summaries, and cross-references).

• If warranted, we file a Notice of Objection to preserve your rights and open an Appeals review.
  

As the file progresses

• We manage Appeals Officer dialogue, supply supplemental evidence, and negotiate resolutions.

• If CRA confirms the reassessment, we prepare your next steps for Tax Court—with timelines and budget laid out so decisions are clear.

How we present your objection so it’s easy to follow

A strong GST/HST objection is not a data dump—it’s a story supported by evidence.

The structure we use:

• Issue statements: Concise questions the decision maker must answer (e.g., Are the ITCs for supplier X allowable despite invoice defects?).

• Facts section: Documented facts with exhibit references (Ex. A12 – Supplier Invoice shows the missing field was corrected and ties to bank payment).

• Law & policy: Relevant Excise Tax Act provisions, CRA policy statements, and case references—only what’s needed.

• Analysis: Why your facts meet the law and where CRA’s assumptions fail.

• Remedy: What variance you seek (e.g., allow ITCs, adjust net tax, remove penalties).
  

Why this works

• Appeals Officers see your logic quickly.

• Each claim is verifiable.

• If the matter escalates, your brief is already court-ready, reducing duplication and cost.

Managing cash-flow risk while the dispute is active

One of the hardest parts of an HST reassessment is that collections may continue even while you object. We plan for stability:

• Balance review: Which amounts are truly in dispute and which can be paid to reduce interest?

• Payment arrangements: We coordinate with CRA on feasible terms where appropriate.

• Security & director risk: We discuss guarantees and director liability exposure so there are no surprises.

• Operational changes: If a coding issue is ongoing, we fix it now to prevent further accruals.

When to fight, when to settle

Not every reassessment should go to the wall. Our goal is outcome clarity, not conflict for its own sake.

• Fight when the law, facts, and documentation align and the variance is meaningful.

• Resolve when the documentation gap can’t be cured or the cost/benefit tilts against prolonged dispute—then negotiate the most efficient path and document the lessons.

Real-world scenarios we see (Toronto & surrounding areas)

• Construction & trades: ITCs denied over subcontractor invoices lacking registration numbers; we obtain corrected invoices and payment proof, then map them to job files.

• Professional services: Place-of-supply errors on cross-province work; we clarify where the service was made and adjust the coding trail.

• Retail & e-commerce: Mismatched merchant deposits vs. reported sales; we reconcile to gateway reports and fix POS mapping.

• Restaurants & hospitality: Mixed-use purchases and gratuity handling; we separate personal use and validate business portions.

• Logistics & importers: Zero-rated supplies and import documentation alignment; we match B3s/CBSA entries to invoices and bank records.
  

Each example is different, but the formula is consistent: clean records + clear reasoning = stronger results.

Our end-to-end service model (built for business owners)

1) Intake & urgency control

• Verify dates, deadlines, and collection status

• Protective filing if needed to secure rights

• Request CRA working papers and notes when useful
  

2) Evidence mapping & gaps plan

• Organized document index (we label each exhibit and link it to the issue it proves)

• Vendor and customer outreach templates for missing confirmations

• Accounting system queries to pull the right reports quickly
  

3) Legal brief & submission

• Position letter in plain language

• Concise legal analysis citing the right provisions and policies

• Submission through the proper CRA channels with proof of filing
  

4) Appeals dialogue & resolution

• Respond to Appeals Officer inquiries

• Narrow issues, agree on facts, and negotiate adjustments

• Written confirmation of any variance or decision
  

5) If needed: Court-ready next steps

• Clear recommendation on whether to appeal to the Tax Court

• Strategy for Informal vs. General Procedure

• Budget and timeline so you can choose with confidence

Why businesses choose Misir & Company for HST reassessment matters

• Specialized in tax disputes. GST/HST objections and appeals are part of our daily work, not a sideline.

• Evidence first. We don’t rely on broad arguments—we build exhibit-driven files.

• Calm, steady communication. You’ll always know where your file stands, what’s next, and why.

• Local and accessible. Serving Toronto & surrounding areas, we can meet in person or work virtually to move fast.

• Future-proofing. We leave you with repeatable controls—invoice templates, coding rules, and close-checklists—to reduce audit risk going forward.

Frequently asked questions

What is the difference between a Notice of Assessment and a Notice of Reassessment for HST?

An Assessment is CRA’s initial determination. A Reassessment replaces part or all of that result after an audit or review. The objection path is similar, but details and amounts change—so we re-evaluate the merits each time.

How long do I have to act after a Notice of Reassessment?

In general, you have 90 days from the date CRA sent the reassessment to file a Notice of Objection for GST/HST. If you’re late, we’ll discuss possible extension routes and what evidence is needed to support them.

Will CRA pause collections during my GST/HST objection?

Collections can continue on GST/HST even during an objection. We address this early—balancing payments that meaningfully reduce interest with the need to keep your business running.

My accountant already prepared the returns—do I still need a lawyer?

Accountants are essential partners. We work with your advisor: they supply accounting detail; we lead the legal submissions, manage Appeals dialogue, and, if required, handle Tax Court steps.

Can you help if I run a small sole-prop and just crossed the registration threshold?

Yes. We’ll determine when registration should have started, how to correct periods, and whether the reassessment can be reduced. We also set up simple controls so it doesn’t happen again.

Your action plan (Toronto & surrounding areas)

If you’re within 90 days

• Share your Notice of Reassessment and the affected return periods.

• We confirm dates, file a Notice of Objection if warranted, and start building your evidence-backed case.

• You’ll receive a status map with milestones and who’s doing what.
  

If you’re past 90 days

• Contact us right away. We’ll assess eligibility for an extension and prepare both the objection and extension request, with reasons and exhibits attached.

What you can expect when you hire us

• A clear, organized file with exhibits that speak for themselves

• Responsible advice on fight vs. settle, grounded in facts and cost/benefit

• Regular updates and date tracking for every deadline

• A result—variance, vacation, or a well-advised court appeal—with no loose ends

About Misir & Company

Address: 880 St Clair Ave West, Toronto, ON, Canada Phone: 416-865-6274

Website: misirandcompany.ca

From our base in Toronto, we help businesses across the GTA navigate HST reassessments, GST/HST objections, and, when needed, Tax Court appeals. Our brand promise is simple: guidance through complexity, delivered with cultural awareness and steady communication.

Ready to move your HST reassessment forward?

Start with a short call. Tell us what changed on your notice and when you received it. We’ll confirm deadlines, map the evidence, and file what’s needed to protect your rights—so you can focus on running the business.

Call 416-865-6274 to begin.

Take the first step today.

Call 416-865-6274 to secure your HST reassessment timeline and start an evidence-backed objection with Misir & Company Lawyers.