6 worked CRA Notice of Objection 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 notice of objection work, not a specific client's file.
Case Study 1 · Sale and succession
$870,000 Sheltered By The Lifetime Capital Gains Exemption — Contractor Facing Reassessment, Kelowna
Client: A contractor facing a proposed reassessment. Where: Kelowna, British Columbia. Engagement: 5 weeks, fixed fee.
Gain sheltered$870,000
ClosingOn schedule
Share qualificationMet
Case 1: the situation
A contractor facing a proposed reassessment in Kelowna, British Columbia had an offer on the table and 27 months to close. The shares did not qualify for the capital gains exemption. A minute book with no resolutions behind a decade of dividends was part of the reason.
Case 1: what we did
We purified the corporation so the shares met the qualifying tests. We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely. All of it was done well ahead of the closing date.
Case 1: the result
The sale closed on schedule with $870,000 sheltered by the lifetime capital gains exemption across the shareholders.
Case Study 2 · Objection and relief
Notice Of Objection Allowed In Full, $82,000 Reversed — Long-Term Non-Filer, Guelph
Client: A taxpayer with eight years of unfiled returns. Where: Guelph, Ontario. Engagement: 8 weeks, fixed fee.
Amount reversed$82,000
ObjectionAllowed in full
Account balanceNil
Case 2: the situation
A taxpayer with eight years of unfiled returns in Guelph, Ontario had been reassessed for $82,000. 18 days were left on the objection deadline. The reassessment rested on a net-worth assessment built on unexplained deposits that were actually loan proceeds.
Case 2: what we did
We filed the objection inside the deadline with a complete submission rather than a placeholder. Alongside it, we kept the waiver narrowed to the issue actually under review and let the remaining years close on the normal reassessment period.
Case 2: the result
The appeals officer allowed the objection in full. $82,000 was reversed and the account returned to a nil balance.
Case Study 3 · Cash and remittance control
$160,000 Of Working Capital Freed From The Tax Cycle — Corporation Under GST/HST Review, Lethbridge
Client: A corporation under a GST/HST review. Where: Lethbridge, Alberta. Engagement: 9 weeks, fixed fee.
Working capital freed$160,000
On-time remittancesEvery period since
Forecast horizon13 weeks
Case 3: the situation
A corporation under a GST/HST review in Lethbridge, Alberta was profitable on paper and short of cash every month. Six years of unfiled corporate and personal returns and an active collections file explained most of the gap.
Case 3: what we did
We requested the auditor’s working papers and report to see how the assessment had been built before answering any of it. We also built a thirteen-week cash view so tax payments stopped competing with payroll for the same dollars.
Case 3: the result
$160,000 was released back into working capital. Remittances have been on time every period since, and the forecast shows the tax outflow before it lands.
Case Study 4 · CRA review defended
$58,000 Reassessment Reduced To Nil On Review — Director Facing Assessment, Toronto
Client: A business owner with a director liability assessment. Where: Toronto, Ontario. Engagement: 8 weeks, fixed fee.
Reassessment reduced toNil
Tax protected$58,000
Prior filingsUndisturbed
Case 4: the situation
A review notice arrived at a business owner with a director liability assessment in Toronto, Ontario, covering CRA notice of objection for two tax years. The auditor's working position was an adjustment of $58,000. It was driven by a proposal letter with a 30-day response window and no supporting records assembled.
Case 4: what we did
Rather than negotiate, we rebuilt the record. We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. We then submitted a point-by-point response that answered each proposed adjustment with the document behind it.
Case 4: the result
The auditor accepted the documented position and closed the review without adjustment, protecting $58,000 and leaving the prior filings undisturbed.
Case Study 5 · Backlog brought current
Collections Halted And $142,000 Cut From A 4-Year Backlog — Professional Under Lifestyle Audit, Calgary
Client: A professional under a lifestyle audit. Where: Calgary, Alberta. Engagement: 3 weeks, fixed fee.
Balance reduced by$142,000
Backlog cleared4 years
CollectionsHalted
Case 5: the situation
By the time a professional under a lifestyle audit in Calgary, Alberta called, 4 years were outstanding. The CRA had assessed on estimates. Underneath it sat a confirmation letter left in a drawer until the appeal window had closed.
Case 5: what we did
We reconstructed the records year by year. 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. Each filing replaced an arbitrary assessment with a real one.
Case 5: the result
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $142,000, and a relief application addressed part of the accumulated interest.
Case Study 6 · Deadline rescue
Filed On Time From A Standing Start, $118,000 Penalty Avoided — Employer Under Payroll Review, Vancouver
Client: A company facing a payroll trust examination. Where: Vancouver, British Columbia. Engagement: 10 weeks, fixed fee.
Penalty avoided$118,000
Turnaround10 weeks
FiledOn time
Case 6: the situation
A company facing a payroll trust examination in Vancouver, British Columbia came to us 10 weeks before its filing deadline. The file came with an audit conducted over the phone, with nothing on file showing what had been provided or when. A late filing would have triggered a penalty of roughly $118,000 before interest.
Case 6: what we did
We worked backwards from the deadline. We filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed. We prioritised the items that actually gated the filing and deferred everything that did not.
Case 6: the result
The return was filed on time and complete. The $118,000 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.
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.
