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CRA letters, decoded

The CRA thinks you should be registered for GST/HST. Now what?

Updated

Quick answer: A registration compliance letter means CRA data, usually your own income tax filings, suggests your taxable revenues crossed the registration threshold; it asks you to register or explain. The real issue is the start date, since the obligation began when the threshold was crossed. Respond with the facts, not the CRA’s guess. Our registration guide covers the mechanics.

If you did cross the threshold, registering late is fixable. We register and backfile together, in that order.

Whether you were required to be registered from that date is the question to settle before you reply. Ask before you respond.

How to handle this CRA letter, in 4 steps: how they knew, then why the start date is the whole game, then if you genuinely were not required, then if you should have registered a while ago
The order to work through it in.
On this page
  1. How they knew
  2. Why the start date is the whole game
  3. If you genuinely were not required
  4. If you should have registered a while ago
  5. Common questions about GST registration letter
  6. Other CRA letters, decoded

How they knew

Your T1 or T2 reports revenue. The GST system knows whether that revenue has a registration attached. When the first says “business income” and the second says “no registrant”, a letter is generated. This is matching, not surveillance, and it means the response has to reconcile with what you already filed.

Why the start date is the whole game

If the threshold was crossed, you were required to register from that point, and tax was collectible on taxable sales from then, whether or not you charged it. A wrong start date can turn into remitting tax you never collected. So the response is a dated revenue walk-through: when the threshold test was met, month by month, from your own records, not a shrug that accepts whatever period the CRA proposes.

If you genuinely were not required

Not all revenue is taxable revenue, and not all activity is commercial activity. If your revenues are exempt, zero-rated in ways that change the analysis, or below the threshold on the correct test, say so with the numbers. The letter is a question, and “no, and here is why” is an available answer when it is true.

If you should have registered a while ago

This is common and recoverable. Registration can be backdated, returns filed for the periods since, and input tax credits from those periods offset some of the liability. Act before the letter’s deadlines, get the dates right, and send us the letter first.

Most registration letters trace back to a threshold nobody was watching, which is part of getting the registrations right at the start.

Fastest first step: email what you’re facing to info@everstonecpa.com — reply within one business day, and we take it from there by email.

General information, not tax advice. The document in your hand and its own dates govern.

Common questions about GST registration letter

What is the registration threshold?+
It is a rolling test on taxable supplies, and the precise mechanics matter more than the headline number — which is why this page sends you to the registration guide rather than quoting a figure that gets misapplied. The letter itself tells you the CRA believes the test was met. Ask about your case →
Do I owe GST on sales where I never charged it?+
If registration was required at the time, the tax was collectible whether or not it was charged — that is why the start date is the whole fight. It is also why responding with your own dated numbers beats accepting a proposed period.
Can I just register today and move on?+
Registering “from today” when the obligation arose earlier does not close the earlier periods — it leaves them open with no filings attached. The clean fix is registration from the correct date with the catch-up returns behind it.
Is this the same as the Voluntary Disclosures Program?+
No — but they can interact. Once the CRA has written to you about the matter, VDP eligibility for it changes, which is exactly why the order of operations deserves advice before any response goes in.

Other CRA letters, decoded

Not sure which letter you have? Start with the full list and match what yours says.

One letter often follows another. These cover the ones owner-managers see most.

Email the letter before you register anything

The start date decides the cost. Get it read first — reply within one business day.

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