Business Reorganization Tax Case Studies

6 Business Reorganization Tax and accounting engagements in full — what the client came to us with, what we did, and what it was worth. Each one is specific to business reorganization tax work, not a general example.

Case Study 1 · Records and systems rebuilt

Month-End Close Cut From 10 Weeks To 4 Days — Manufacturer Developing a Production, Brampton

Client: A manufacturer developing a production process  ·  Where: Brampton, Ontario  ·  Engagement: 9 weeks, fixed fee

Close time before10 weeks
Close time after4 days
Year-endReview, not rebuild

The situation

The accounting file at a manufacturer developing a production process in Brampton, Ontario was built on a claim filed at the 15% non-refundable rate when CCPC status supported 35% refundable. The year-end had taken 10 weeks each of the last three years.

What we did

We layered the applicable provincial credit onto the federal claim in the same filing and moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.

The result

The file reconciles. Month-end closes in 4 days instead of 10 weeks, and the year-end is a review rather than a reconstruction.

Case Study 2 · Scaling without breaking

Scaled To 24 Staff With $21,000 Of Working Capital Freed — Industrial Automation Integrator, Vancouver

Client: An industrial automation integrator  ·  Where: Vancouver, British Columbia  ·  Engagement: 11 weeks, fixed fee

Headcount reached24
Working capital freed$21,000
Missed deadlinesZero

The situation

An industrial automation integrator in Vancouver, British Columbia was growing fast — headcount to 24 in eighteen months — and the back office had not kept up. A SR&ED claim prepared eleven months after the fact with no contemporaneous records was the first thing to break.

What we did

We put contemporaneous tracking in place — project logs tied to time records — so the following year’s claim was defensible by construction, and built the compliance calendar for the size the business was becoming rather than the size it had been.

The result

The business reached 24 staff with no missed remittance and no late filing. $21,000 of working capital was freed in the process.

Case Study 3 · Sale and succession

$685,000 Sheltered By The Lifetime Capital Gains Exemption — Agri-Tech Company, Kitchener

Client: An agri-tech company  ·  Where: Kitchener, Ontario  ·  Engagement: 8 weeks, fixed fee

Gain sheltered$685,000
ClosingOn schedule
Share qualificationMet

The situation

An agri-tech company in Kitchener, Ontario had an offer on the table and 19 months to close. The shares did not qualify for the capital gains exemption, and a minute book with no resolutions behind a decade of dividends was part of the reason.

What we did

We purified the corporation so the shares met the qualifying tests, then identified the eligible projects, documented the technological uncertainty and systematic investigation for each, and filed a claim that survived review without adjustment well ahead of the closing date.

The result

The sale closed on schedule with $685,000 sheltered by the lifetime capital gains exemption across the shareholders.

Case Study 4 · Objection and relief

Notice Of Objection Allowed In Full, $127,000 Reversed — Medical Device Developer, Edmonton

Client: A medical device developer  ·  Where: Edmonton, Alberta  ·  Engagement: 8 weeks, fixed fee

Amount reversed$127,000
ObjectionAllowed in full
Account balanceNil

The situation

A medical device developer in Edmonton, Alberta had been reassessed for $127,000 and had 20 days left on the objection deadline. The reassessment rested on a filing deadline missed by three weeks, extinguishing the entire claim.

What we did

We filed the objection inside the deadline with a complete submission rather than a placeholder, and confirmed CCPC status and refiled at the enhanced 35% refundable rate.

The result

The appeals officer allowed the objection in full. $127,000 was reversed and the account returned to a nil balance.

Case Study 5 · Cash and remittance control

Remittance Schedule Corrected, $65,000 Refunded — Engineering Firm Solving a, Victoria

Client: An engineering firm solving a technical uncertainty  ·  Where: Victoria, British Columbia  ·  Engagement: 8 weeks, fixed fee

Overpayment refunded$65,000
Late remittances sinceZero
ScheduleAutomated

The situation

Remittances at an engineering firm solving a technical uncertainty in Victoria, British Columbia were consistently late by a few days, which was enough to trigger penalties every quarter. Behind it sat a provincial credit left unclaimed alongside a successful federal SR&ED claim.

What we did

We layered the applicable provincial credit onto the federal claim in the same filing, then moved the remittance dates into a scheduled process rather than a monthly decision.

The result

Penalties stopped from the following remittance onwards, and $65,000 of overpaid instalments was refunded.

Case Study 6 · CRA review defended

Audit Defence Closed In 3 Weeks, $55,000 Cleared — Food Producer Reformulating Its, Winnipeg

Client: A food producer reformulating its product line  ·  Where: Winnipeg, Manitoba  ·  Engagement: 3 weeks, fixed fee

Proposed tax cleared$55,000
Review duration3 weeks
OutcomeNo change

The situation

A food producer reformulating its product line in Winnipeg, Manitoba was selected for review after a claim filed at the 15% non-refundable rate when CCPC status supported 35% refundable showed up in the CRA's automated matching. The proposed adjustment on business reorganization tax came to $55,000.

What we did

We put contemporaneous tracking in place — project logs tied to time records — so the following year’s claim was defensible by construction. Every figure in the response traced to a source record the auditor could verify without asking a second question.

The result

The review closed with no change. $55,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.

Reviewed for the 2025 tax year by Udit Gupta, Certified Tax Accountant. Figures describe representative engagements of this type; outcomes depend on your own facts. Client names and identifying details are omitted for confidentiality.

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