CRA Review Letter Response Case Studies

6 worked CRA Review Letter Response 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 review letter response work, not a specific client's file.

Case Study 1 · Deadline rescue

$26,500 Late-Filing Penalty Cancelled On Relief Application — Employer Under Payroll Review, Saskatoon

Client: A company facing a payroll trust examination  ·  Where: Saskatoon, Saskatchewan  ·  Engagement: 3 weeks, fixed fee

Penalty cancelled$26,500
Relief applicationGranted
ReturnAccepted as filed

The situation — A company facing a payroll trust examination, Saskatoon, Saskatchewan

A company facing a payroll trust examination in Saskatoon, Saskatchewan 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. A penalty of $26,500 was accruing.

What we did for A company facing a payroll trust examination, Saskatoon, Saskatchewan

We split the work into what had to happen before the deadline and what could follow it. Then we 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filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn.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 company facing a payroll trust examination, Saskatoon, Saskatchewan

The outstanding return was accepted as filed, and the taxpayer relief application cancelled $26,500 of the penalty already assessed on the earlier year.

Case Study 2 · Missed incentive claimed

$131,000 In Credits Claimed That Prior Filings Had Missed — Taxpayer Relief Applicant, Brampton

Client: A taxpayer applying for relief from penalties and interest  ·  Where: Brampton, Ontario  ·  Engagement: 7 weeks, fixed fee

Credits claimed$131,000
Years adjusted6
Review outcomeNo adjustment

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

A taxpayer applying for relief from penalties and interest in Brampton, Ontario had been filing for 6 years. In that time, the incentives its activity qualified for were never claimed. Behind that sat an audit conducted over the phone, with nothing on file showing what had been provided or when.

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

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 applying for relief from penalties and interest, Brampton, Ontario

$131,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.

Case Study 3 · Records and systems rebuilt

14 Months Reconciled And $12,500 Of Input Tax Recovered — Taxpayer Facing Collections, Red Deer

Client: A taxpayer with frozen bank accounts  ·  Where: Red Deer, Alberta  ·  Engagement: 4 weeks, fixed fee

Months reconciled14
Input tax recovered$12,500
Close time4 days

The situation — A taxpayer with frozen bank accounts, Red Deer, Alberta

Nothing reconciled at a taxpayer with frozen bank accounts in Red Deer, Alberta. Every filing started with 14 months of cleanup. The file was carrying a net-worth assessment built on unexplained deposits that were actually loan proceeds.

What we did for A taxpayer with frozen bank accounts, Red Deer, Alberta

We rebuilt from source rather than correcting on top of the existing file. We filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed. Then we set the routine that keeps it clean.

The result — A taxpayer with frozen bank accounts, Red Deer, Alberta

14 months reconciled to the bank. The close now takes 4 days, and $12,500 of previously unclaimable input tax was recovered in the process.

Case Study 4 · Sale and succession

Intergenerational Transfer Completed With $320,000 Deferred — Restaurant Under Net-Worth Audit, Moncton

Client: A restaurant under a net-worth audit  ·  Where: Moncton, New Brunswick  ·  Engagement: 6 weeks, fixed fee

Tax deferred$320,000
TransferCompleted
RecordsReview-ready

The situation — A restaurant under a net-worth audit, Moncton, New Brunswick

A generational transfer at a restaurant under a net-worth audit in Moncton, New Brunswick had been discussed for years without a plan. Retained cash well above what the business needed to operate meant the transfer as contemplated would have been fully taxable.

What we did for A restaurant under a net-worth audit, Moncton, New Brunswick

We kept the waiver narrowed to the issue actually under review and let the remaining years close on the normal reassessment period. We sequenced the steps so each one was complete and documented before the next depended on it.

The result — A restaurant under a net-worth audit, Moncton, New Brunswick

$320,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.

Case Study 5 · Cash and remittance control

$55,000 Of Working Capital Freed From The Tax Cycle — Family Business Under Review, Guelph

Client: A family business under a related-party review  ·  Where: Guelph, Ontario  ·  Engagement: 4 weeks, fixed fee

Working capital freed$55,000
On-time remittancesEvery period since
Forecast horizon13 weeks

The situation — A family business under a related-party review, Guelph, Ontario

A family business under a related-party review in Guelph, Ontario was profitable on paper and short of cash every month. An objection deadline that had passed with no extension applied for explained most of the gap.

What we did for A family business under a related-party review, Guelph, Ontario

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. We also built a thirteen-week cash view so tax payments stopped competing with payroll for the same dollars.

The result — A family business under a related-party review, Guelph, Ontario

$55,000 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 6 · Backlog brought current

4 Years Filed, $80,000 Removed From The Assessed Balance — Contractor Facing Reassessment, Calgary

Client: A contractor facing a proposed reassessment  ·  Where: Calgary, Alberta  ·  Engagement: 7 weeks, fixed fee

Years filed4
Assessed balance removed$80,000
CollectionsStopped

The situation — A contractor facing a proposed reassessment, Calgary, Alberta

A contractor facing a proposed reassessment in Calgary, Alberta had not filed for 4 years. The CRA had issued arbitrary assessments. The business was carrying six years of unfiled corporate and personal returns and an active collections file. That came on top of a growing interest balance.

What we did for A contractor facing a proposed reassessment, Calgary, Alberta

We started with the oldest year and worked forward so each year's closing balances fed the next. We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely. We filed the years in sequence rather than all at once.

The result — A contractor facing a proposed reassessment, Calgary, Alberta

Every year is now filed and assessed on actual figures. The notional assessments were vacated and $80,000 of the estimated balance came off, with a payment arrangement covering the rest.

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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