6 worked CRA Appeals Assistance 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 cra appeals assistance work, not a specific client's file.
Case Study 1 · Backlog brought current
Collections Halted And $138,000 Cut From A 3-Year Backlog — Late-Objection Taxpayer, Barrie
Client: A taxpayer whose objection window has closed · Where: Barrie, Ontario · Engagement: 4 weeks, fixed fee
Balance reduced by$138,000
Backlog cleared3 years
CollectionsHalted
The situation — A taxpayer whose objection window has closed, Barrie, Ontario
By the time a taxpayer whose objection window has closed in Barrie, Ontario called, 3 years were outstanding and the CRA had assessed on estimates. Underneath it sat a net-worth assessment built on unexplained deposits that were actually loan proceeds.
What we did for A taxpayer whose objection window has closed, Barrie, Ontario
We reconstructed the records year by year and traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. Each filing replaced an arbitrary assessment with a real one.
The result — A taxpayer whose objection window has closed, Barrie, Ontario
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $138,000, and a relief application addressed part of the accumulated interest.
Case Study 2 · Structure rebuilt
Corporate Structure Rebuilt For $23,000 Of Annual Savings — Employer Under Payroll Review, Victoria
Client: A company facing a payroll trust examination · Where: Victoria, British Columbia · Engagement: 3 weeks, fixed fee
Saving per year$23,000
DocumentationComplete
Transfer basisRollover
The situation — A company facing a payroll trust examination, Victoria, British Columbia
The structure at a company facing a payroll trust examination in Victoria, British Columbia had been set up years earlier for a business that no longer existed, and an objection deadline that had passed with no extension applied for had become expensive.
What we did for A company facing a payroll trust examination, Victoria, British Columbia
We filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result — A company facing a payroll trust examination, Victoria, British Columbia
$23,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 3 · Objection and relief
Desk-Review Assessment Of $83,000 Vacated — Long-Term Non-Filer, Regina
Client: A taxpayer with eight years of unfiled returns · Where: Regina, Saskatchewan · Engagement: 9 weeks, fixed fee
Assessment vacated$83,000
Supporting recordsNow on file
AccountCleared
The situation — A taxpayer with eight years of unfiled returns, Regina, Saskatchewan
A taxpayer with eight years of unfiled returns in Regina, Saskatchewan was carrying $83,000 of penalties and interest arising from an audit conducted over the phone, with nothing on file showing what had been provided or when, much of it accumulated during a period the CRA itself had delayed.
What we did for A taxpayer with eight years of unfiled returns, Regina, Saskatchewan
We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely and framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A taxpayer with eight years of unfiled returns, Regina, Saskatchewan
The assessment was vacated. $83,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 4 · Deadline rescue
$100,000 Late-Filing Penalty Cancelled On Relief Application — Assessed Shareholder, London
Client: A shareholder assessed on a taxable benefit · Where: London, Ontario · Engagement: 3 weeks, fixed fee
Penalty cancelled$100,000
Relief applicationGranted
ReturnAccepted as filed
The situation — A shareholder assessed on a taxable benefit, London, Ontario
A shareholder assessed on a taxable benefit in London, Ontario had already missed one deadline and was about to miss a second. Behind it sat a proposal letter with a 30-day response window and no supporting records assembled, and a penalty of $100,000 was accruing.
What we did for A shareholder assessed on a taxable benefit, London, Ontario
We split the work into what had to happen before the deadline and what could follow it, then requested the auditor’s working papers and report to see how the assessment had been built before answering any of it.
The result — A shareholder assessed on a taxable benefit, London, Ontario
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $100,000 of the penalty already assessed on the earlier year.
Case Study 5 · Records and systems rebuilt
Month-End Close Cut From 9 Weeks To 6 Days — Family Business Under Review, Surrey
Client: A family business under a related-party review · Where: Surrey, British Columbia · Engagement: 3 weeks, fixed fee
Close time before9 weeks
Close time after6 days
Year-endReview, not rebuild
The situation — A family business under a related-party review, Surrey, British Columbia
The accounting file at a family business under a related-party review in Surrey, British Columbia was built on a director liability assessment for a corporation that had already stopped operating. The year-end had taken 9 weeks each of the last three years.
What we did for A family business under a related-party review, Surrey, British Columbia
We answered each query in writing with an indexed document package, so the file showed exactly what the auditor had received and on what date and moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.
The result — A family business under a related-party review, Surrey, British Columbia
The file reconciles. Month-end closes in 6 days instead of 9 weeks, and the year-end is a review rather than a reconstruction.
Case Study 6 · Cash and remittance control
Instalments Rebased, $117,000 Of Cash Returned To The Business — Director Facing Assessment, Ottawa
Client: A business owner with a director liability assessment · Where: Ottawa, Ontario · Engagement: 10 weeks, fixed fee
Cash returned$117,000
Instalment basisCurrent year
ReviewedQuarterly
The situation — A business owner with a director liability assessment, Ottawa, Ontario
A business owner with a director liability assessment in Ottawa, Ontario was paying instalments calculated on a prior year that no longer reflected the business. A waiver signed at the counter that kept an otherwise closed year open with no end date was tying up $117,000 of cash.
What we did for A business owner with a director liability assessment, Ottawa, Ontario
We rebased the instalments on the current-year estimate rather than the prior-year default, and assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn.
The result — A business owner with a director liability assessment, Ottawa, Ontario
$117,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.
Reviewed for the 2025 tax year by Udit Gupta, Founder and Tax Accountant. 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.
