6 worked Corporate Dissolution Tax Return case studies — the position a client typically comes to us with, what we do, and what it is worth. Each is an illustrative example built on the rules that apply to corporate dissolution tax return work, not a specific client's file.
Case Study 1 · Objection and relief
Desk-Review Assessment Of $43,000 Vacated — Family Business Adding Shares, Guelph
Client: A family business adding a second class of shares · Where: Guelph, Ontario · Engagement: 3 weeks, fixed fee
Assessment vacated$43,000
Supporting recordsNow on file
AccountCleared
The situation — A family business adding a second class of shares, Guelph, Ontario
A family business adding a second class of shares in Guelph, Ontario was carrying $43,000 of penalties and interest. The charges arose from GST/HST collected for eight months before the RT account was ever opened. Much of that amount accumulated during a period the CRA itself had delayed.
What we did for A family business adding a second class of shares, Guelph, Ontario
We tested each intended dividend recipient against the excluded-amount tests before any dividend was declared, and recorded which test was being relied on. We framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A family business adding a second class of shares, Guelph, Ontario
The assessment was vacated. $43,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 2 · Records and systems rebuilt
Books Rebuilt From Source, $14,000 In Unclaimed Input Tax Found — New Program Registrant, Lethbridge
Client: A corporation registering its CRA program accounts · Where: Lethbridge, Alberta · Engagement: 3 weeks, fixed fee
Unclaimed tax found$14,000
Records rebuilt31 months
ProcessDocumented
The situation — A corporation registering its CRA program accounts, Lethbridge, Alberta
A corporation registering its CRA program accounts in Lethbridge, Alberta could not answer basic questions about its own numbers. A December 31 year-end chosen by default that put the balance due at the worst point in the cash cycle sat between the bank statements and the ledger.
What we did for A corporation registering its CRA program accounts, Lethbridge, Alberta
We restructured the share capital so dividends could be directed deliberately, respecting the TOSI rules. We then documented the process so the work does not depend on any one person remembering how it was done.
The result — A corporation registering its CRA program accounts, Lethbridge, Alberta
Records rebuilt and reconciled, $14,000 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.
Case Study 3 · Planning that cut the bill
$28,000 Cut From The Annual Tax Bill — Holding Structure Founder, Toronto
Client: A founder setting up a holding structure · Where: Toronto, Ontario · Engagement: 5 weeks, fixed fee
First-year saving$28,000
RepeatsAnnually
Filing positionUnchanged in risk
The situation — A founder setting up a holding structure, Toronto, Ontario
A founder setting up a holding structure in Toronto, Ontario was compliant but paying more than it needed to. The prior year had been filed correctly. It still left a register of individuals with significant control that had never been opened, let alone updated on the table.
What we did for A founder setting up a holding structure, Toronto, Ontario
We modelled the current position against the alternatives before changing anything. Then we reconstructed the minute book with resolutions for each historical dividend and share transaction.
The result — A founder setting up a holding structure, Toronto, Ontario
The change saved $28,000 in the first year and repeats annually. Nothing about the filings became more aggressive. The position is simply the one the rules already allowed.
Case Study 4 · CRA review defended
$78,000 Reassessment Reduced To Nil On Review — Pre-Investment Startup, Calgary
Client: A startup preparing for its first investment round · Where: Calgary, Alberta · Engagement: 8 weeks, fixed fee
Reassessment reduced toNil
Tax protected$78,000
Prior filingsUndisturbed
The situation — A startup preparing for its first investment round, Calgary, Alberta
A review notice arrived at a startup preparing for its first investment round in Calgary, Alberta, covering corporate dissolution tax return for two tax years. The auditor's working position was an adjustment of $78,000. It was driven by a single class of common shares that made income splitting impossible.
What we did for A startup preparing for its first investment round, Calgary, Alberta
Rather than negotiate, we rebuilt the record. We selected a year-end that put the balance-due date after the seasonal cash peak, then registered every program account the business actually needed. We then submitted a point-by-point response that answered each proposed adjustment with the document behind it.
The result — A startup preparing for its first investment round, Calgary, Alberta
The auditor accepted the documented position and closed the review without adjustment, protecting $78,000 and leaving the prior filings undisturbed.
Case Study 5 · Sale and succession
Share Sale Restructured, $565,000 Less Tax On Closing — Federal Registry Filer, Vancouver
Client: A federal corporation filing its registry annual return · Where: Vancouver, British Columbia · Engagement: 4 weeks, fixed fee
Tax saved on closing$565,000
PriceAs agreed
Post-closing adjustmentsNone
The situation — A federal corporation filing its registry annual return, Vancouver, British Columbia
A federal corporation filing its registry annual return in Vancouver, British Columbia was preparing to sell. Due diligence surfaced no valuation on file to support the price the parties had agreed. That would have reduced the price or killed the deal outright.
What we did for A federal corporation filing its registry annual return, Vancouver, British Columbia
We cleaned up the historical file. We revived the corporation, filed the outstanding annual returns, and set a compliance calendar covering both the corporate registry and the CRA. Then we prepared the due-diligence package the buyer's advisers actually asked for.
The result — A federal corporation filing its registry annual return, Vancouver, British Columbia
The deal closed at the agreed price. $565,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.
Case Study 6 · Structure rebuilt
Corporate Structure Rebuilt For $50,000 Of Annual Savings — Provincially Incorporating Trades Business, Mississauga
Client: A trades business incorporating provincially · Where: Mississauga, Ontario · Engagement: 8 weeks, fixed fee
Saving per year$50,000
DocumentationComplete
Transfer basisRollover
The situation — A trades business incorporating provincially, Mississauga, Ontario
The structure at a trades business incorporating provincially in Mississauga, Ontario dated from years earlier. It had been set up for a business that no longer existed. A spouse added as a shareholder on the assumption dividends could simply be split between two returns had become expensive.
What we did for A trades business incorporating provincially, Mississauga, Ontario
We separated the corporate registry deadlines from the CRA deadlines on one calendar, with a named person responsible for each. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result — A trades business incorporating provincially, Mississauga, Ontario
$50,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Reviewed by Udit Gupta, Founder and Tax Accountant for the 2025 tax year. These case studies are illustrative worked examples composed from the CRA rules that apply to this type of work, not specific client files; figures are representative and outcomes depend on your own facts.
