6 worked Corporate Tax 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 work, not a specific client's file.
Case Study 1 · Sale and succession
Share Sale Restructured, $575,000 Less Tax On Closing — Second-Generation Manufacturer, Mississauga
Client: A second-generation family manufacturer · Where: Mississauga, Ontario · Engagement: 7 weeks, fixed fee
Tax saved on closing$575,000
PriceAs agreed
Post-closing adjustmentsNone
The situation — A second-generation family manufacturer, Mississauga, Ontario
A second-generation family manufacturer in Mississauga, Ontario was preparing to sell. Due diligence surfaced a minute book with no resolutions behind a decade of dividends. That would have reduced the price or killed the deal outright.
What we did for A second-generation family manufacturer, Mississauga, Ontario
We cleaned up the historical file. We moved passive holdings into a separate structure so the operating company’s small business limit stopped grinding down. Then we prepared the due-diligence package the buyer's advisers actually asked for.
The result — A second-generation family manufacturer, Mississauga, Ontario
The deal closed at the agreed price. $575,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.
Case Study 2 · CRA review defended
$86,000 Proposed Adjustment Withdrawn In Full — Associated Corporation Pair, Brampton
Client: A corporation associated with a spouse-owned company · Where: Brampton, Ontario · Engagement: 8 weeks, fixed fee
Adjustment withdrawn$86,000
File closed in8 weeks
Penalties assessedNone
The situation — A corporation associated with a spouse-owned company, Brampton, Ontario
A corporation associated with a spouse-owned company in Brampton, Ontario received a proposal letter opening a review of corporate tax. The CRA had identified two corporations under common control filing as if each had its own $500,000 limit. It proposed an adjustment of $86,000, with 30 days to respond.
What we did for A corporation associated with a spouse-owned company, Brampton, Ontario
We treated the response as an evidence exercise rather than an argument. 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 then indexed every supporting document against the specific line the auditor had questioned.
The result — A corporation associated with a spouse-owned company, Brampton, Ontario
The proposed adjustment was withdrawn in full — all $86,000 of it. The file closed in 8 weeks with no change to the assessed amounts and no penalty.
Case Study 3 · Planning that cut the bill
$49,000 Saved By Correcting What Prior Filings Had Missed — Three-Location Franchisee, Lethbridge
Client: A franchise operator with three locations · Where: Lethbridge, Alberta · Engagement: 3 weeks, fixed fee
Saving identified$49,000
RecurringYes
Positions documentedAll
The situation — A franchise operator with three locations, Lethbridge, Alberta
A franchise operator with three locations in Lethbridge, Alberta asked for a second opinion on corporate tax. That followed three years of rising tax. The review found a loss year carried forward by default when carrying it back would have produced a refund cheque.
What we did for A franchise operator with three locations, Lethbridge, Alberta
We built the comparison first: current structure against two alternatives. Then we rebuilt the instalment schedule off the current year rather than the prior year, ending the interest accrual.
The result — A franchise operator with three locations, Lethbridge, Alberta
First-year saving of $49,000, with the same benefit recurring. Every position taken is documented and supported in the file.
Case Study 4 · Records and systems rebuilt
Month-End Close Cut From 11 Weeks To 8 Days — Corporation Holding Investments, Halifax
Client: An operating company holding surplus investments · Where: Halifax, Nova Scotia · Engagement: 9 weeks, fixed fee
Close time before11 weeks
Close time after8 days
Year-endReview, not rebuild
The situation — An operating company holding surplus investments, Halifax, Nova Scotia
The accounting file at an operating company holding surplus investments in Halifax, Nova Scotia had a weak foundation. It was built on dividends moved up to a holding company year after year with no safe-income support on file. The year-end had taken 11 weeks each of the last three years.
What we did for An operating company holding surplus investments, Halifax, Nova Scotia
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 also moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.
The result — An operating company holding surplus investments, Halifax, Nova Scotia
The file reconciles. Month-end closes in 8 days instead of 11 weeks, and the year-end is a review rather than a reconstruction.
Case Study 5 · Objection and relief
Desk-Review Assessment Of $91,000 Vacated — Incorporated Consultancy, Moncton
Client: An incorporated consultancy · Where: Moncton, New Brunswick · Engagement: 4 weeks, fixed fee
Assessment vacated$91,000
Supporting recordsNow on file
AccountCleared
The situation — An incorporated consultancy, Moncton, New Brunswick
An incorporated consultancy in Moncton, New Brunswick was carrying $91,000 of penalties and interest. The charges arose from a balance-due date the owner believed was the same as the filing date. Much of that amount accumulated during a period the CRA itself had delayed.
What we did for An incorporated consultancy, Moncton, New Brunswick
We modelled salary against dividends across both the corporation and the shareholder’s personal return, then set the remuneration mix for the year. We framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — An incorporated consultancy, Moncton, New Brunswick
The assessment was vacated. $91,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 6 · Backlog brought current
Collections Halted And $130,000 Cut From A 4-Year Backlog — Instalment-Paying Corporation, Ottawa
Client: A corporation paying instalments on prior-year figures · Where: Ottawa, Ontario · Engagement: 4 weeks, fixed fee
Balance reduced by$130,000
Backlog cleared4 years
CollectionsHalted
The situation — A corporation paying instalments on prior-year figures, Ottawa, Ontario
By the time a corporation paying instalments on prior-year figures in Ottawa, Ontario called, 4 years were outstanding. The CRA had assessed on estimates. Underneath it sat retained earnings building in the operating company with no plan for extracting them.
What we did for A corporation paying instalments on prior-year figures, Ottawa, Ontario
We reconstructed the records year by year. 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. Each filing replaced an arbitrary assessment with a real one.
The result — A corporation paying instalments on prior-year figures, Ottawa, Ontario
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $130,000, and a relief application addressed part of the accumulated interest.
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.
