CRA Audit Representation Case Studies

6 CRA Audit Representation tax and accounting engagements in full — what the client came to us with, what we did, and what it was worth. Each one is specific to cra audit representation work, not a general example.

Case Study 1 · Deadline rescue

$127,000 Late-Filing Penalty Cancelled On Relief Application — Company Facing a Payroll, Red Deer

Client: A company facing a payroll trust examination  ·  Where: Red Deer, Alberta  ·  Engagement: 10 weeks, fixed fee

Penalty cancelled$127,000
Relief applicationGranted
ReturnAccepted as filed

The situation

A company facing a payroll trust examination in Red Deer, Alberta had already missed one deadline and was about to miss a second. Behind it sat a net-worth assessment built on unexplained deposits that were actually loan proceeds, and a penalty of $127,000 was accruing.

What we did

We split the work into what had to happen before the deadline and what could follow it, then traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly.

The result

The outstanding return was accepted as filed, and the taxpayer relief application cancelled $127,000 of the penalty already assessed on the earlier year.

Case Study 2 · Sale and succession

$435,000 Sheltered By The Lifetime Capital Gains Exemption — Business Owner with a, Victoria

Client: A business owner with a director liability assessment  ·  Where: Victoria, British Columbia  ·  Engagement: 8 weeks, fixed fee

Gain sheltered$435,000
ClosingOn schedule
Share qualificationMet

The situation

A business owner with a director liability assessment in Victoria, British Columbia had an offer on the table and 29 months to close. The shares did not qualify for the capital gains exemption, and no valuation on file to support the price the parties had agreed was part of the reason.

What we did

We purified the corporation so the shares met the qualifying tests, then assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn well ahead of the closing date.

The result

The sale closed on schedule with $435,000 sheltered by the lifetime capital gains exemption across the shareholders.

Case Study 3 · Planning that cut the bill

$19,500 Cut From The Annual Tax Bill — Taxpayer with Eight Years, Windsor

Client: A taxpayer with eight years of unfiled returns  ·  Where: Windsor, Ontario  ·  Engagement: 4 weeks, fixed fee

First-year saving$19,500
RepeatsAnnually
Filing positionUnchanged in risk

The situation

A taxpayer with eight years of unfiled returns in Windsor, Ontario was compliant but paying more than it needed to. The prior year had been filed correctly and still left a director liability assessment for a corporation that had already stopped operating on the table.

What we did

We modelled the current position against the alternatives before changing anything, then filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely.

The result

The change saved $19,500 in the first year and repeats annually. Nothing about the filings became more aggressive; the position is simply the one the rules already allowed.

Case Study 4 · Objection and relief

Desk-Review Assessment Of $129,000 Vacated — Restaurant Under a Net-Worth, Moncton

Client: A restaurant under a net-worth audit  ·  Where: Moncton, New Brunswick  ·  Engagement: 10 weeks, fixed fee

Assessment vacated$129,000
Supporting recordsNow on file
AccountCleared

The situation

A restaurant under a net-worth audit in Moncton, New Brunswick was carrying $129,000 of penalties and interest arising from six years of unfiled corporate and personal returns and an active collections file, much of it accumulated during a period the CRA itself had delayed.

What we did

We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action and framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.

The result

The assessment was vacated. $129,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.

Case Study 5 · Missed incentive claimed

Incentive Review Recovered $48,000 Across 7 Open Years — Family Business Under a, Barrie

Client: A family business under a related-party review  ·  Where: Barrie, Ontario  ·  Engagement: 8 weeks, fixed fee

Recovered$48,000
Open years claimed7
Ongoing trackingIn place

The situation

An incentive review at a family business under a related-party review in Barrie, Ontario started from a simple question: what has never been claimed? The answer ran to 7 years, driven by a director liability assessment for a corporation that had already stopped operating.

What we did

We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly, documenting eligibility to the standard a reviewer would apply rather than the standard a claim form requires.

The result

The credits produced $48,000 across the open years, and the tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.

Case Study 6 · Cash and remittance control

$64,000 Of Working Capital Freed From The Tax Cycle — Taxpayer with Frozen Bank, Kelowna

Client: A taxpayer with frozen bank accounts  ·  Where: Kelowna, British Columbia  ·  Engagement: 6 weeks, fixed fee

Working capital freed$64,000
On-time remittancesEvery period since
Forecast horizon13 weeks

The situation

A taxpayer with frozen bank accounts in Kelowna, British Columbia was profitable on paper and short of cash every month. A net-worth assessment built on unexplained deposits that were actually loan proceeds explained most of the gap.

What we did

We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn and built a thirteen-week cash view so tax payments stopped competing with payroll for the same dollars.

The result

$64,000 was released back into working capital. Remittances have been on time every period since, and the forecast shows the tax outflow before it lands.

Reviewed for the 2025 tax year by Udit Gupta, Certified Tax Accountant. Figures describe representative engagements of this type; outcomes depend on your own facts. Client names and identifying details are omitted for confidentiality.

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