6 worked Corporate Tax Planning 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 planning work, not a specific client's file.
Case Study 1 · Structure rebuilt
Corporate Structure Rebuilt For $74,000 Of Annual Savings — Second-Generation Manufacturer, Halifax
Client: A second-generation family manufacturer · Where: Halifax, Nova Scotia · Engagement: 5 weeks, fixed fee
Saving per year$74,000
DocumentationComplete
Transfer basisRollover
The situation — A second-generation family manufacturer, Halifax, Nova Scotia
The structure at a second-generation family manufacturer in Halifax, Nova Scotia dated from years earlier. It had been set up for a business that no longer existed. Dividends moved up to a holding company year after year with no safe-income support on file had become expensive.
What we did for A second-generation family manufacturer, Halifax, Nova Scotia
We reviewed each capital cost allowance pool and set the claim at the level that kept the small business deduction fully used rather than wasted. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result — A second-generation family manufacturer, Halifax, Nova Scotia
$74,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Client: A technology CCPC approaching its first profitable year · Where: Brampton, Ontario · Engagement: 8 weeks, fixed fee
Overpayment refunded$91,000
Late remittances sinceZero
ScheduleAutomated
The situation — A technology CCPC approaching its first profitable year, Brampton, Ontario
Remittances at a technology CCPC approaching its first profitable year in Brampton, Ontario were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat passive investment income that had crossed the $50,000 grind threshold unnoticed.
What we did for A technology CCPC approaching its first profitable year, Brampton, Ontario
We modelled salary against dividends across both the corporation and the shareholder’s personal return, then set the remuneration mix for the year. Then we moved the remittance dates into a scheduled process rather than a monthly decision.
The result — A technology CCPC approaching its first profitable year, Brampton, Ontario
Penalties stopped from the following remittance onwards, and $91,000 of overpaid instalments was refunded.
Case Study 3 · Missed incentive claimed
$77,000 Credit Claim Filed And Accepted Without Adjustment — Corporation Holding Investments, Victoria
Client: An operating company holding surplus investments · Where: Victoria, British Columbia · Engagement: 7 weeks, fixed fee
Claim value$77,000
AcceptedWithout adjustment
RepeatableAnnually
The situation — An operating company holding surplus investments, Victoria, British Columbia
An operating company holding surplus investments in Victoria, British Columbia assumed the credits did not apply to a business its size. Dividends moved up to a holding company year after year with no safe-income support on file meant they had applied all along.
What we did for An operating company holding surplus investments, Victoria, British Columbia
We identified the qualifying activity and built the documentation to support it. Then we mapped the association rules across the group, allocated the business limit deliberately on Schedule 23, and corrected the prior year by adjustment request.
The result — An operating company holding surplus investments, Victoria, British Columbia
$77,000 recovered. Because the eligibility analysis is on file, the same claim can be repeated each year with a fraction of the effort.
Case Study 4 · Objection and relief
Desk-Review Assessment Of $23,500 Vacated — Holding and Operating Companies, Kelowna
Client: A holding company and its operating subsidiary · Where: Kelowna, British Columbia · Engagement: 7 weeks, fixed fee
Assessment vacated$23,500
Supporting recordsNow on file
AccountCleared
The situation — A holding company and its operating subsidiary, Kelowna, British Columbia
A holding company and its operating subsidiary in Kelowna, British Columbia was carrying $23,500 of penalties and interest. The charges arose from a loss year carried forward by default when carrying it back would have produced a refund cheque. Much of that amount accumulated during a period the CRA itself had delayed.
What we did for A holding company and its operating subsidiary, Kelowna, British Columbia
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 framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A holding company and its operating subsidiary, Kelowna, British Columbia
The assessment was vacated. $23,500 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 5 · Planning that cut the bill
$65,000 Saved By Correcting What Prior Filings Had Missed — Incorporated Consultancy, Calgary
Client: An incorporated consultancy · Where: Calgary, Alberta · Engagement: 3 weeks, fixed fee
Saving identified$65,000
RecurringYes
Positions documentedAll
The situation — An incorporated consultancy, Calgary, Alberta
An incorporated consultancy in Calgary, Alberta asked for a second opinion on corporate tax planning. That followed three years of rising tax. The review found a small business limit quietly shared across three associated corporations nobody had mapped.
What we did for An incorporated consultancy, Calgary, Alberta
We built the comparison first: current structure against two alternatives. Then we moved passive holdings into a separate structure so the operating company’s small business limit stopped grinding down.
The result — An incorporated consultancy, Calgary, Alberta
First-year saving of $65,000, with the same benefit recurring. Every position taken is documented and supported in the file.
Case Study 6 · Sale and succession
Intergenerational Transfer Completed With $615,000 Deferred — Import and Distribution Corporation, Ottawa
Client: An import and distribution corporation · Where: Ottawa, Ontario · Engagement: 11 weeks, fixed fee
Tax deferred$615,000
TransferCompleted
RecordsReview-ready
The situation — An import and distribution corporation, Ottawa, Ontario
A generational transfer at an import and distribution corporation in Ottawa, Ontario had been discussed for years without a plan. No valuation on file to support the price the parties had agreed meant the transfer as contemplated would have been fully taxable.
What we did for An import and distribution corporation, Ottawa, Ontario
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 sequenced the steps so each one was complete and documented before the next depended on it.
The result — An import and distribution corporation, Ottawa, Ontario
$615,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
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.
