CRA Withholding Tax Audit Support (Reg 105 / Reg 102)

CRA Withholding Tax Audit Support (Reg 105 / Reg 102)

At Larivco & Cie, we help businesses respond to—and proactively prepare for—CRA reviews and audits involving withholding tax under Regulation 105 (non-resident contractors) and Regulation 102 (non-resident employees). When CRA asks questions, speed and documentation matter. We bring structure to the process, reduce disruption to your finance/payroll teams, and help you defend your position with a clear, consistent file.

Audit readiness review (before CRA escalates)

If you suspect exposure—or you want to be prepared—we start with an audit readiness assessment:

• review of payment flows, contracts, and work performed in Canada

• testing whether withholding and remittances were applied correctly

• identification of documentation gaps and high-risk patterns
  This gives you a practical view of what CRA is likely to focus on and where to reinforce the file.

Response strategy + document production (organized and defensible)

When you receive CRA queries, an audit letter, or an information request, we help you respond with a clear strategy:

• define the technical position (Reg 105 vs Reg 102, scope, timelines)

• build a document index and production package (contracts, invoices, travel logs, work location evidence, payroll support, waiver/certification records)

• draft responses that are consistent, factual, and aligned with CRA expectations
  Our goal is to reduce back-and-forth and keep the audit contained.

Risk remediation plan (fix what caused the issue)

Audits often reveal process weaknesses (vendor onboarding, invoice structure, missing support, inconsistent remittance practices). We provide a remediation plan that is easy to implement:

• updated withholding decision rules

• improved AP/Payroll controls

• documentation standards and retention checklists

• training notes for Finance/HR teams
  This helps prevent repeat findings and strengthens compliance going forward.