6 worked Corporation Dissolution 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 corporation dissolution work, not a specific client's file.
Case Study 1 · CRA review defended
$24,000 Proposed Adjustment Withdrawn In Full — Incorporating Contractor, Burnaby
Client: A contractor incorporating for liability reasons · Where: Burnaby, British Columbia · Engagement: 5 weeks, fixed fee
Adjustment withdrawn$24,000
File closed in5 weeks
Penalties assessedNone
The situation — A contractor incorporating for liability reasons, Burnaby, British Columbia
A contractor incorporating for liability reasons in Burnaby, British Columbia received a proposal letter opening a review of corporation dissolution. The CRA had identified dividends paid for three years with no directors’ resolutions behind them. It proposed an adjustment of $24,000, with 30 days to respond.
What we did for A contractor incorporating for liability reasons, Burnaby, British Columbia
We treated the response as an evidence exercise rather than an argument. We reconstructed the minute book with resolutions for each historical dividend and share transaction. We then indexed every supporting document against the specific line the auditor had questioned.
The result — A contractor incorporating for liability reasons, Burnaby, British Columbia
The proposed adjustment was withdrawn in full — all $24,000 of it. The file closed in 5 weeks with no change to the assessed amounts and no penalty.
Case Study 2 · Missed incentive claimed
$96,000 Credit Claim Filed And Accepted Without Adjustment — Federally Incorporating Seller, Victoria
Client: An e-commerce seller incorporating federally · Where: Victoria, British Columbia · Engagement: 7 weeks, fixed fee
Claim value$96,000
AcceptedWithout adjustment
RepeatableAnnually
The situation — An e-commerce seller incorporating federally, Victoria, British Columbia
An e-commerce seller incorporating federally in Victoria, British Columbia assumed the credits did not apply to a business its size. Dividends paid for three years with no directors’ resolutions behind them meant they had applied all along.
What we did for An e-commerce seller incorporating federally, Victoria, British Columbia
We identified the qualifying activity and built the documentation to support it. Then we tested each intended dividend recipient against the excluded-amount tests before any dividend was declared, and recorded which test was being relied on.
The result — An e-commerce seller incorporating federally, Victoria, British Columbia
$96,000 recovered. Because the eligibility analysis is on file, the same claim can be repeated each year with a fraction of the effort.
Case Study 3 · Sale and succession
$880,000 Sheltered By The Lifetime Capital Gains Exemption — Newly Incorporating Consultant, Guelph
Client: A consultant incorporating after two years of self-employment · Where: Guelph, Ontario · Engagement: 8 weeks, fixed fee
Gain sheltered$880,000
ClosingOn schedule
Share qualificationMet
The situation — A consultant incorporating after two years of self-employment, Guelph, Ontario
A consultant incorporating after two years of self-employment in Guelph, Ontario had an offer on the table and 14 months to close. The shares did not qualify for the capital gains exemption. Passive assets sitting inside the operating company, disqualifying the shares was part of the reason.
What we did for A consultant incorporating after two years of self-employment, Guelph, Ontario
We purified the corporation so the shares met the qualifying tests. We filed the change of registered office and the director changes, so registry correspondence reached someone who read it. All of it was done well ahead of the closing date.
The result — A consultant incorporating after two years of self-employment, Guelph, Ontario
The sale closed on schedule with $880,000 sheltered by the lifetime capital gains exemption across the shareholders.
Case Study 4 · Backlog brought current
Collections Halted And $86,000 Cut From A 6-Year Backlog — Newly Formed Corporation, Mississauga
Client: A corporation choosing its first fiscal year-end · Where: Mississauga, Ontario · Engagement: 6 weeks, fixed fee
Balance reduced by$86,000
Backlog cleared6 years
CollectionsHalted
The situation — A corporation choosing its first fiscal year-end, Mississauga, Ontario
By the time a corporation choosing its first fiscal year-end in Mississauga, Ontario called, 6 years were outstanding. The CRA had assessed on estimates. Underneath it sat a registered office address left unchanged through two moves, so registry notices went to an empty unit.
What we did for A corporation choosing its first fiscal year-end, Mississauga, Ontario
We reconstructed the records year by year. We revived the corporation, filed the outstanding annual returns, and set a compliance calendar covering both the corporate registry and the CRA. Each filing replaced an arbitrary assessment with a real one.
The result — A corporation choosing its first fiscal year-end, Mississauga, Ontario
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $86,000, and a relief application addressed part of the accumulated interest.
Case Study 5 · Structure rebuilt
Corporate Structure Rebuilt For $10,000 Of Annual Savings — Family Business Adding Shares, Surrey
Client: A family business adding a second class of shares · Where: Surrey, British Columbia · Engagement: 6 weeks, fixed fee
Saving per year$10,000
DocumentationComplete
Transfer basisRollover
The situation — A family business adding a second class of shares, Surrey, British Columbia
The structure at a family business adding a second class of shares in Surrey, British Columbia dated from years earlier. It had been set up for a business that no longer existed. A register of individuals with significant control that had never been opened, let alone updated had become expensive.
What we did for A family business adding a second class of shares, Surrey, British Columbia
We restructured the share capital so dividends could be directed deliberately, respecting the TOSI rules. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result — A family business adding a second class of shares, Surrey, British Columbia
$10,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 6 · Objection and relief
$135,000 Of Penalties And Interest Cancelled On Relief — Holding Structure Founder, Brampton
Client: A founder setting up a holding structure · Where: Brampton, Ontario · Engagement: 6 weeks, fixed fee
Penalties and interest cancelled$135,000
Relief groundsAccepted
AssessmentAdjusted to filed position
The situation — A founder setting up a holding structure, Brampton, Ontario
An assessment of $135,000 landed at a founder setting up a holding structure in Brampton, Ontario following a desk review. It turned on a spouse added as a shareholder on the assumption dividends could simply be split between two returns. The auditor had not seen the records behind it.
What we did for A founder setting up a holding structure, Brampton, Ontario
We opened the register of individuals with significant control and put its review on the same annual cycle as the corporate annual return. We then set out the legislative basis for the position alongside the documents supporting it.
The result — A founder setting up a holding structure, Brampton, Ontario
$135,000 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.
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.
