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CRA, Compliance & Changing Accountants

Switching accountants: what should you ask your old accountant for?

Ask for five things: copies of everything filed, with the notices of assessment; the financial statements and the adjusting entries behind them; the continuity schedules, capital cost allowance, losses, capital dividend account, shareholder loans; copies of any elections and rollover filings; and your own bookkeeping data and source documents. Your records must be handed back, unpaid-fee dispute or not, though the accountant’s own working papers are generally theirs to keep. Send the request in writing before the handover starts, because the balances on that list are exactly what your new CPA cannot rebuild cheaply.

A CPA walking a business owner through the numbers on a tablet

The request list, in the order it matters

The list is best organized by how expensive each item is to reconstruct if it never arrives. Filed returns and government correspondence can be recovered from CRA if you must; the continuity schedules behind them often cannot, because they live only in the old accountant's files. Here is the request we send, and who typically holds each piece:

What to requestWhy it mattersWho usually holds it
Filed T2s, HST returns, T4/T5 summaries, with notices of assessmentConfirms what CRA actually has, and which years are still openOld accountant; CRA online as backup
Financial statements and adjusting journal entries, every yearThe entries bridge your books to the statements; without them the two never reconcileOld accountant only
Capital cost allowance schedules by asset classUndepreciated capital cost balances carry forward forever and are costly to rebuildOld accountant only
Tax pool continuities: losses, capital dividend account, refundable tax and GRIP balancesThese decide future tax-free and low-tax payouts; a lost balance is lost moneyOld accountant; some figures visible to CRA
Shareholder loan continuity and share ACB/PUC historyProtects you personally on draws, repayments and any future sale or estate workOld accountant only
Copies of elections and rollovers, T2057s and similar, with the supporting valuationsPast reorganizations set today's cost bases; the paper is the proofOld accountant; sometimes your lawyer
Your bookkeeping file and source documentsThe data is yours; access often sits under the accountant's subscriptionTransferred to you or your new CPA
Open CRA correspondence, reviews and instalment statusDeadlines keep running through the handoverOld accountant and CRA

Two items owners forget because they never see them: the depreciation and pool schedules, and the adjusting entries. Neither appears in your software or your CRA account in usable form, and both are pure institutional memory. If you get only one email answered, make it the one asking for those.

What is yours, and what stays with the accountant

Your records come back to you; the accountant's working papers generally do not, and knowing the line keeps the handover civil. Everything you provided, source documents, contracts, bank records, and everything produced as a deliverable you engaged them for, filed returns, financial statements, belongs on your side. The analysis they built to get there, checklists, review notes, internal memos, is typically their property, and CPAs also have their own retention obligations that make them keep it. In practice, most professionals will happily share continuity schedules with a successor because it is normal courtesy; the distinction matters mainly when a relationship has soured.

A fee dispute does not change your side of the line. Under CPA Ontario's professional conduct expectations, records belonging to the client should be returned regardless of outstanding fees; an accountant may decline to hand over their own work product until paid, but holding your source documents or your data file hostage is not a position the profession supports. Our advice is still to settle the final invoice promptly, because the difference between a two-day handover and a two-month one is usually goodwill, not rules.

If you have concluded the relationship is over but have not yet said so, sequence matters: line up the new firm first, then request records, then close out. The wider sequencing, notice, timing around year-end and who files what in the transition year, is covered in how to change accountants without disrupting your business, and if you are still deciding whether to move at all, start with the signs you have outgrown your current accountant.

The balances that must not get lost in the move

Carry-forward balances are where switching accountants silently costs money, because a balance nobody transfers is a balance nobody claims. The capital dividend account is the sharpest example: it can allow tax-free capital dividends to shareholders, CRA does not track a running figure you can simply look up and rely on, and it is computed from the corporation's whole history, so the prior accountant's continuity schedule is genuinely valuable paper. Loss carryforwards expire on schedules; undepreciated capital cost set today's deductions; refundable tax balances decide what a dividend releases; the adjusted cost base of your shares decides tax on a future sale, and each of these lives in a working paper, not on a government statement.

The same applies to elections. If the corporation has ever done a rollover or reorganization, the election forms and the valuations behind them are the proof of every cost base they created, and they matter most years later, at a sale, an estate freeze or an audit, exactly when the old accountant's files may no longer exist. Get copies now, while they are one email away, and have the new firm verify what it inherits: a good onboarding reperforms or sanity-checks the key continuities rather than accepting them, which is part of what a new CPA should review during onboarding.

How the handover actually works

The mechanics are more standardized than owners expect, because the profession has rules for exactly this moment. When you engage a new CPA firm, it is required to write to the predecessor before accepting the engagement, asking whether there is any reason it should not act, and the predecessor is expected to respond; that same exchange is the natural vehicle for the records request, which is why the transfer usually needs one authorization from you and little chasing. Put your own request in writing anyway, with the list above attached, so nothing depends on the firms' interpretation of scope.

The CRA side runs in parallel. Your new representative is authorized through CRA's Represent a Client system, on your approval, and the old firm's authorization should be cancelled at the same time, otherwise CRA correspondence keeps flowing to an office with no mandate to act on it. Same idea for any provincial accounts and your bookkeeping subscriptions: transfer the billing and admin roles, do not just add a user. Where mail has already gone astray during a sloppy transition, notices, reviews, demands to file, catching up with CRA and re-establishing who speaks for the corporation is routine CRA Support work, and doing it fast matters because objection and response deadlines do not pause for handovers.

One more mechanic: retention stays your obligation throughout. Corporate records must be kept for six years from the end of the last tax year they relate to, and the duty sits with the corporation, not with whoever happened to prepare the filings. When the old firm eventually destroys its file on its own schedule, entirely within its rights, your copies are the ones that must still exist, which is the real reason the request list above is worth an afternoon now.

What changes the answer for your handover

How much of the list matters, and how hard to push for it, depends on a few facts:

  • The corporation's age and history, since a two-year-old company has little continuity to lose and a fifteen-year-old one with a reorganization has a lot
  • Whether elections or rollovers were ever filed, because those papers are irreplaceable at sale or estate time
  • Who owns the bookkeeping subscription, since a file under the accountant's account needs a deliberate transfer, not a goodbye
  • The state of the relationship, a cooperative predecessor changing the timeline more than any rule does
  • Open CRA matters, because reviews and instalment schedules keep their deadlines mid-handover
  • Timing against your year-end, which decides who files the current year and what they need to do it

We handle incoming files with a standard records request, a verification pass on the key continuities, and a first-year calendar, the same CRA support and corporate compliance work an Ontario CPA should bring to every takeover, inside an Ongoing Financial Partnership when the fit is right. If you are mid-switch and unsure what to ask for, a free 15-minute discovery call gets you the list tailored to your file.

Common questions

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Can my old accountant withhold my records because of an unpaid invoice?

Your own records, no: source documents, your data file and the deliverables you engaged them for should come back regardless of a fee dispute, and CPA Ontario’s conduct expectations support that. Their internal working papers are a different matter, and they may hold their own analysis until paid, which is one practical reason we suggest settling the final invoice promptly rather than fighting on principle.

What if the old accountant has closed shop or simply will not respond?

Recover what CRA holds first: filed returns, assessments, statements of account and correspondence are available through Represent a Client once your new CPA is authorized. The genuinely private pieces, adjusting entries, CCA schedules and pool continuities, then get rebuilt from your bank records, filings and history, which is slower but entirely doable, and a normal part of onboarding a neglected file.

How long does my corporation have to keep the old records after switching?

Six years from the end of the last tax year they relate to, and the obligation belongs to the corporation, not to whichever accountant prepared the filings. Your former firm will destroy its file on its own retention schedule, so the copies you collect at handover are the ones that must still exist if CRA reviews an old year.

Keep reading

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Changing accountants smoothly

The full switch sequence this records request belongs inside.

Visit page

Signs you have outgrown your accountant

Whether to make the move at all, before you request anything.

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End-to-End Accounting

What the file looks like once one team runs all of it.

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