CRA Clearance Certificate Assistance Case Studies

6 worked CRA Clearance Certificate 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 clearance certificate assistance work, not a specific client's file.

Case Study 1 · Planning that cut the bill

$22,500 Cut From The Annual Tax Bill — Assessed Shareholder, Regina

Client: A shareholder assessed on a taxable benefit  ·  Where: Regina, Saskatchewan  ·  Engagement: 5 weeks, fixed fee

First-year saving$22,500
RepeatsAnnually
Filing positionUnchanged in risk

The situation — A shareholder assessed on a taxable benefit, Regina, Saskatchewan

A shareholder assessed on a taxable benefit in Regina, Saskatchewan was compliant but paying more than it needed to. The prior year had been filed correctly. It still left an objection deadline that had passed with no extension applied for on the table.

What we did for A shareholder assessed on a taxable benefit, Regina, Saskatchewan

We modelled the current position against the alternatives before changing anything. Then 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.

The result — A shareholder assessed on a taxable benefit, Regina, Saskatchewan

The change saved $22,500 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 2 · CRA review defended

Audit Defence Closed In 7 Weeks, $15,000 Cleared — Corporation Under GST/HST Review, Toronto

Client: A corporation under a GST/HST review  ·  Where: Toronto, Ontario  ·  Engagement: 7 weeks, fixed fee

Proposed tax cleared$15,000
Review duration7 weeks
OutcomeNo change

The situation — A corporation under a GST/HST review, Toronto, Ontario

A corporation under a GST/HST review in Toronto, Ontario was selected for review. A proposal letter with a 30-day response window and no supporting records assembled had shown up in the CRA's automated matching. The proposed adjustment on CRA clearance certificate assistance came to $15,000.

What we did for A corporation under a GST/HST review, Toronto, Ontario

We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. Every figure in the response traced to a source record the auditor could verify without asking a second question.

The result — A corporation under a GST/HST review, Toronto, Ontario

The review closed with no change. $15,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.

Case Study 3 · Sale and succession

Intergenerational Transfer Completed With $180,000 Deferred — Family Business Under Review, Saskatoon

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

Tax deferred$180,000
TransferCompleted
RecordsReview-ready

The situation — A family business under a related-party review, Saskatoon, Saskatchewan

A generational transfer at a family business under a related-party review in Saskatoon, Saskatchewan had been discussed for years without a plan. Passive assets sitting inside the operating company, disqualifying the shares meant the transfer as contemplated would have been fully taxable.

What we did for A family business under a related-party review, Saskatoon, Saskatchewan

We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn. We sequenced the steps so each one was complete and documented before the next depended on it.

The result — A family business under a related-party review, Saskatoon, Saskatchewan

$180,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.

Case Study 4 · Structure rebuilt

Reorganisation Completed Tax-Deferred, $43,000 Saved Each Year — Taxpayer Relief Applicant, Barrie

Client: A taxpayer applying for relief from penalties and interest  ·  Where: Barrie, Ontario  ·  Engagement: 10 weeks, fixed fee

Annual saving$43,000
Tax on reorganisationDeferred
Elections filedOn time

The situation — A taxpayer applying for relief from penalties and interest, Barrie, Ontario

A taxpayer applying for relief from penalties and interest in Barrie, Ontario had outgrown the structure it started with. Six years of unfiled corporate and personal returns and an active collections file was the immediate problem. The longer-term one was that the structure blocked the next step.

What we did for A taxpayer applying for relief from penalties and interest, Barrie, Ontario

We mapped the current structure and modelled the target. Then we filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed. The tax-deferred elections were filed on time and the supporting valuations documented.

The result — A taxpayer applying for relief from penalties and interest, Barrie, Ontario

The reorganisation completed without triggering tax, and the new structure saves approximately $43,000 a year while removing the exposure the old one carried.

Case Study 5 · Deadline rescue

11-Week Turnaround Beat The Deadline And Saved $114,000 — Director Facing Assessment, Winnipeg

Client: A business owner with a director liability assessment  ·  Where: Winnipeg, Manitoba  ·  Engagement: 11 weeks, fixed fee

Late-filing penalty avoided$114,000
Filed with20 days to spare
Next yearPapers ready

The situation — A business owner with a director liability assessment, Winnipeg, Manitoba

A business owner with a director liability assessment in Winnipeg, Manitoba was weeks away from the deadline for CRA clearance certificate assistance. Behind that sat an audit conducted over the phone, with nothing on file showing what had been provided or when. The exposure if the date slipped was around $114,000.

What we did for A business owner with a director liability assessment, Winnipeg, Manitoba

We kept the waiver narrowed to the issue actually under review and let the remaining years close on the normal reassessment period. The filing went in complete rather than provisional, so there was no amended return to follow.

The result — A business owner with a director liability assessment, Winnipeg, Manitoba

Filed with 20 days to spare. $114,000 in late-filing penalties avoided, and the working papers are ready for the following year.

Case Study 6 · Cash and remittance control

Instalments Rebased, $19,000 Of Cash Returned To The Business — Importer Under Audit, Red Deer

Client: An importer under a customs and GST audit  ·  Where: Red Deer, Alberta  ·  Engagement: 8 weeks, fixed fee

Cash returned$19,000
Instalment basisCurrent year
ReviewedQuarterly

The situation — An importer under a customs and GST audit, Red Deer, Alberta

An importer under a customs and GST audit in Red Deer, Alberta was paying instalments calculated on a prior year. That year no longer reflected the business. A net-worth assessment built on unexplained deposits that were actually loan proceeds was tying up $19,000 of cash.

What we did for An importer under a customs and GST audit, Red Deer, Alberta

We rebased the instalments on the current-year estimate rather than the prior-year default. Alongside that, we filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely.

The result — An importer under a customs and GST audit, Red Deer, Alberta

$19,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.

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.

Sources. CRA — Businesses · Income Tax Act (Justice Laws Website)

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