6 worked CRA Payment Arrangement 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 payment arrangement work, not a specific client's file.
Case Study 1 · Scaling without breaking
Second-Province Expansion Handled, $132,000 Of Cash Released — Restaurant Under Net-Worth Audit, Surrey
Client: A restaurant under a net-worth audit · Where: Surrey, British Columbia · Engagement: 9 weeks, fixed fee
Cash released$132,000
New registrationsComplete on day one
Compliance gapsNone
The situation — A restaurant under a net-worth audit, Surrey, British Columbia
Revenue at a restaurant under a net-worth audit in Surrey, British Columbia was up sharply and cash was tighter than ever. Underneath it sat an audit conducted over the phone, with nothing on file showing what had been provided or when.
What we did for A restaurant under a net-worth audit, Surrey, British Columbia
We filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed. Every new obligation was set up before it was triggered, not after. That covered registration, remittance frequency and provincial filing.
The result — A restaurant under a net-worth audit, Surrey, British Columbia
$132,000 of cash was released from the working capital cycle. The expansion completed with every registration and filing obligation covered from day one.
Case Study 2 · Missed incentive claimed
$88,000 In Credits Claimed That Prior Filings Had Missed — Taxpayer Facing Collections, Burnaby
Client: A taxpayer with frozen bank accounts · Where: Burnaby, British Columbia · Engagement: 11 weeks, fixed fee
Credits claimed$88,000
Years adjusted6
Review outcomeNo adjustment
The situation — A taxpayer with frozen bank accounts, Burnaby, British Columbia
A taxpayer with frozen bank accounts in Burnaby, British Columbia had been filing for 6 years. In that time, the incentives its activity qualified for were never claimed. Behind that sat a waiver signed at the counter that kept an otherwise closed year open with no end date.
What we did for A taxpayer with frozen bank accounts, Burnaby, British Columbia
We tested each activity against the eligibility criteria rather than the description on the invoice. Then we requested the auditor’s working papers and report to see how the assessment had been built before answering any of it.
The result — A taxpayer with frozen bank accounts, Burnaby, British Columbia
$88,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 3 · Backlog brought current
$13,000 Of Arbitrary Assessments Vacated After 6 Years — Contractor Facing Reassessment, Red Deer
Client: A contractor facing a proposed reassessment · Where: Red Deer, Alberta · Engagement: 6 weeks, fixed fee
Arbitrary tax vacated$13,000
Years brought current6
Account statusCurrent
The situation — A contractor facing a proposed reassessment, Red Deer, Alberta
6 years of unfiled returns had turned into notional assessments at a contractor facing a proposed reassessment in Red Deer, Alberta. Underneath lay a net-worth assessment built on unexplained deposits that were actually loan proceeds. Collections had already started.
What we did for A contractor facing a proposed reassessment, Red Deer, Alberta
We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn. We then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.
The result — A contractor facing a proposed reassessment, Red Deer, Alberta
All 6 years were accepted as filed. $13,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 6 years.
Case Study 4 · Objection and relief
Desk-Review Assessment Of $78,000 Vacated — Family Business Under Review, Barrie
Client: A family business under a related-party review · Where: Barrie, Ontario · Engagement: 9 weeks, fixed fee
Assessment vacated$78,000
Supporting recordsNow on file
AccountCleared
The situation — A family business under a related-party review, Barrie, Ontario
A family business under a related-party review in Barrie, Ontario was carrying $78,000 of penalties and interest. The charges arose from a proposal letter with a 30-day response window and no supporting records assembled. Much of that amount accumulated during a period the CRA itself had delayed.
What we did for A family business under a related-party review, Barrie, Ontario
We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. We framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A family business under a related-party review, Barrie, Ontario
The assessment was vacated. $78,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 5 · Records and systems rebuilt
Books Rebuilt From Source, $19,000 In Unclaimed Input Tax Found — Long-Term Non-Filer, Toronto
Client: A taxpayer with eight years of unfiled returns · Where: Toronto, Ontario · Engagement: 9 weeks, fixed fee
Unclaimed tax found$19,000
Records rebuilt32 months
ProcessDocumented
The situation — A taxpayer with eight years of unfiled returns, Toronto, Ontario
A taxpayer with eight years of unfiled returns in Toronto, Ontario could not answer basic questions about its own numbers. A confirmation letter left in a drawer until the appeal window had closed sat between the bank statements and the ledger.
What we did for A taxpayer with eight years of unfiled returns, Toronto, Ontario
We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. We then documented the process so the work does not depend on any one person remembering how it was done.
The result — A taxpayer with eight years of unfiled returns, Toronto, Ontario
Records rebuilt and reconciled, $19,000 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.
Case Study 6 · Planning that cut the bill
$36,500 Cut From The Annual Tax Bill — Importer Under Audit, Edmonton
Client: An importer under a customs and GST audit · Where: Edmonton, Alberta · Engagement: 8 weeks, fixed fee
First-year saving$36,500
RepeatsAnnually
Filing positionUnchanged in risk
The situation — An importer under a customs and GST audit, Edmonton, Alberta
An importer under a customs and GST audit in Edmonton, Alberta was compliant but paying more than it needed to. The prior year had been filed correctly. It still left a waiver signed at the counter that kept an otherwise closed year open with no end date on the table.
What we did for An importer under a customs and GST audit, Edmonton, Alberta
We modelled the current position against the alternatives before changing anything. Then 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, Edmonton, Alberta
The change saved $36,500 in the first year and repeats annually. Nothing about the filings became more aggressive. The position is simply the one the rules already allowed.
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.
