6 worked Corporate Tax Debt Resolution 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 tax debt resolution work, not a specific client's file.
Case Study 1 · Structure rebuilt
Corporate Structure Rebuilt For $33,500 Of Annual Savings — Incorporated Trades Business, Burnaby
Client: An incorporated trades business · Where: Burnaby, British Columbia · Engagement: 8 weeks, fixed fee
Saving per year$33,500
DocumentationComplete
Transfer basisRollover
The situation — An incorporated trades business, Burnaby, British Columbia
The structure at an incorporated trades business in Burnaby, British Columbia dated from years earlier. It had been set up for a business that no longer existed. A balance-due date the owner believed was the same as the filing date had become expensive.
What we did for An incorporated trades business, Burnaby, British Columbia
We rebuilt the instalment schedule off the current year rather than the prior year, ending the interest accrual. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result — An incorporated trades business, Burnaby, British Columbia
$33,500 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 2 · Scaling without breaking
Growth Handled Without A Missed Filing, $88,000 Freed — Incorporated Consultancy, Red Deer
Client: An incorporated consultancy · Where: Red Deer, Alberta · Engagement: 7 weeks, fixed fee
Cash freed$88,000
Compliance failuresNone
ReportingMonthly
The situation — An incorporated consultancy, Red Deer, Alberta
An incorporated consultancy in Red Deer, Alberta was opening in a second province. That meant different filing obligations and a different payroll regime. Passive investment income that had crossed the $50,000 grind threshold unnoticed already sat in the file.
What we did for An incorporated consultancy, Red Deer, Alberta
We carried the non-capital loss back against the two profitable years and recovered tax already paid instead of holding a carry-forward balance. We then put monthly reporting in place. That let the owner see the cash effect of growth while there was still time to act on it.
The result — An incorporated consultancy, Red Deer, Alberta
Growth was absorbed without a compliance failure. $88,000 of cash was released, and the monthly reporting now flags a problem while it is still small.
Case Study 3 · Objection and relief
Desk-Review Assessment Of $87,000 Vacated — Professional Corporation, Barrie
Client: A professional corporation · Where: Barrie, Ontario · Engagement: 4 weeks, fixed fee
Assessment vacated$87,000
Supporting recordsNow on file
AccountCleared
The situation — A professional corporation, Barrie, Ontario
A professional corporation in Barrie, Ontario was carrying $87,000 of penalties and interest. The charges arose from a small business limit quietly shared across three associated corporations nobody had mapped. Much of that amount accumulated during a period the CRA itself had delayed.
What we did for A professional corporation, Barrie, Ontario
We documented safe income before the inter-corporate dividend was paid, so subsection 55(2) had no room to recharacterise it as a gain. We framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A professional corporation, Barrie, Ontario
The assessment was vacated. $87,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 4 · CRA review defended
Audit Defence Closed In 7 Weeks, $109,000 Cleared — Non-Calendar Year-End Corporation, Toronto
Client: A corporation with a non-calendar fiscal year-end · Where: Toronto, Ontario · Engagement: 7 weeks, fixed fee
Proposed tax cleared$109,000
Review duration7 weeks
OutcomeNo change
The situation — A corporation with a non-calendar fiscal year-end, Toronto, Ontario
A corporation with a non-calendar fiscal year-end in Toronto, Ontario was selected for review. Dividends moved up to a holding company year after year with no safe-income support on file had shown up in the CRA's automated matching. The proposed adjustment on corporate tax debt resolution came to $109,000.
What we did for A corporation with a non-calendar fiscal year-end, Toronto, Ontario
We mapped the association rules across the group, allocated the business limit deliberately on Schedule 23, and corrected the prior year by adjustment request. Every figure in the response traced to a source record the auditor could verify without asking a second question.
The result — A corporation with a non-calendar fiscal year-end, Toronto, Ontario
The review closed with no change. $109,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.
Case Study 5 · Deadline rescue
5-Week Turnaround Beat The Deadline And Saved $73,000 — Associated Corporation Pair, Edmonton
Client: A corporation associated with a spouse-owned company · Where: Edmonton, Alberta · Engagement: 5 weeks, fixed fee
Late-filing penalty avoided$73,000
Filed with22 days to spare
Next yearPapers ready
The situation — A corporation associated with a spouse-owned company, Edmonton, Alberta
A corporation associated with a spouse-owned company in Edmonton, Alberta was weeks away from the deadline for corporate tax debt resolution. Behind that sat a distribution treated as tax-free capital dividend with no election ever filed. The exposure if the date slipped was around $73,000.
What we did for A corporation associated with a spouse-owned company, Edmonton, Alberta
We modelled salary against dividends across both the corporation and the shareholder’s personal return, then set the remuneration mix for the year. The filing went in complete rather than provisional, so there was no amended return to follow.
The result — A corporation associated with a spouse-owned company, Edmonton, Alberta
Filed with 22 days to spare. $73,000 in late-filing penalties avoided, and the working papers are ready for the following year.
Case Study 6 · Missed incentive claimed
Incentive Review Recovered $73,000 Across 6 Open Years — First-Profit Technology CCPC, Surrey
Client: A technology CCPC approaching its first profitable year · Where: Surrey, British Columbia · Engagement: 6 weeks, fixed fee
Recovered$73,000
Open years claimed6
Ongoing trackingIn place
The situation — A technology CCPC approaching its first profitable year, Surrey, British Columbia
An incentive review at a technology CCPC approaching its first profitable year in Surrey, British Columbia started from a simple question: what has never been claimed? The answer ran to 6 years. It was driven by retained earnings building in the operating company with no plan for extracting them.
What we did for A technology CCPC approaching its first profitable year, Surrey, British Columbia
We reconstructed the capital dividend account from the underlying transactions and filed the subsection 83(2) election before the next distribution left the company. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result — A technology CCPC approaching its first profitable year, Surrey, British Columbia
The credits produced $73,000 across the open years. The tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.
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.
