CRA Trust Accounts Examination: Payroll and GST/HST Records to Prepare
A practical preparation guide for a CRA trust accounts examination focused on payroll deductions and GST/HST, including requested records, reconciliation steps, and response controls.
Quick answer
What Calgary business owners should know
- A CRA trust accounts examination focuses on amounts held in trust, such as payroll deductions withheld and GST/HST collected, and is different from a general income tax audit.
- Read the CRA request carefully, verify the officer's identity, identify the periods and program accounts, and confirm the secure submission method.
- Reconcile payroll and GST/HST returns to the general ledger, bank activity, source documents, and CRA account transactions before sending records.
- Keep an indexed copy of every record provided and a dated log of questions, submissions, confirmations, and follow-up items.
Understand the examination's scope
The CRA uses the term trust accounts examination for a review of payroll and GST/HST obligations. Its guidance says the examination may verify employment income and taxable benefits, source deductions and employer contributions, GST/HST collection and remittance, filing requirements, and worker characterization. The officer's request should identify the program accounts, periods, and specific records required.
Do not assume the scope from a phone call alone. Verify the contact using official CRA information, preserve the original notice, and appoint one responsible contact. If a requested item or date is unclear, ask the officer for clarification in writing where possible. A professional preparer can assist, but the business remains responsible for its obligations and records.
| Record group | Examples | Reconciliation objective |
|---|---|---|
| Payroll | Payroll registers, employee files, taxable-benefit support, T4 slips and summaries | Tie gross pay, deductions, benefits, and year-end reporting together |
| Remittances | PD7A information, payment confirmations, CRA account statements | Match amounts and dates to payroll periods and the assigned remitter type |
| GST/HST | Sales journals, invoices, returns, ITC invoices, adjustment support | Reconcile tax collected and credits claimed to the ledger and returns |
| Bank and ledger | Bank statements, deposits, cancelled cheques, receivable and payable ledgers | Trace cash movement and reported amounts to accounting records |
| Workers and contracts | Employment agreements, contractor invoices, duties, control, tools, and payment records | Support how worker status and payments were treated |
Reconcile each program account before responding
For payroll, tie each pay period to the payroll register, general ledger, bank payment, deductions, employer CPP and EI contributions, remittance, and year-end slips. Investigate differences such as manual cheques, bonuses, taxable benefits, voids, off-cycle payments, or corrections. For GST/HST, reconcile taxable sales, tax collected, adjustments, input tax credits, return totals, payments, and CRA account activity.
Create a difference schedule rather than hiding unresolved items. State the amount, period, cause, evidence, corrective action, and whether the CRA has already processed a change. When records are missing, disclose the gap and explain the reconstruction method. Do not alter original source documents or create a false trail.
Practical checklist
- Use the exact periods and program accounts in the CRA request.
- Trace totals from source documents through the ledger to each filed return.
- Separate payroll, GST/HST, corporate tax, and personal records in the response index.
- Redact only where appropriate and permitted; do not remove information the CRA lawfully requested.
- Send records through the method authorized by the CRA officer and retain proof.
Control communications and follow-up
Maintain a response log with the request date, due date, officer, requested items, file names, submission date, confirmation, questions, and follow-up. Keep the submitted copy separate from working drafts. If the officer asks for additional records, add them to the same index and record why they were requested.
Review any proposed adjustment against the records and ask for an explanation of unresolved differences. A trust examination can raise tax, payroll, worker-status, or legal issues requiring specialized advice. This guide does not predict an outcome or replace advice based on the actual CRA request.
- Which existing HBT guides can help organize payroll and GST/HST records?
The payroll setup guide and GST/HST return guide explain the recurring records that should connect to remittances and returns. They can be used as orientation before the actual CRA request is reviewed.
Review the Calgary employer payroll checklist- Where can a business review GST/HST return support?
HBT Accounting's GST/HST guide explains return preparation and input tax credit evidence at a general level.
Review the GST/HST returns and ITCs guide
Official sources
This guide was prepared from the official sources below. Open them to verify the current rule and review exceptions relevant to your situation.