CRA Tax-Debt Assistance Case Studies

6 worked CRA Tax-Debt 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 tax-debt assistance work, not a specific client's file.

Case Study 1 · CRA review defended

Audit Defence Closed In 10 Weeks, $29,000 Cleared — Taxpayer Relief Applicant, Brampton

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

Proposed tax cleared$29,000
Review duration10 weeks
OutcomeNo change

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 was selected for review after a director liability assessment for a corporation that had already stopped operating showed up in the CRA's automated matching. The proposed adjustment on cra tax-debt assistance came to $29,000.

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

We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely. Every figure in the response traced to a source record the auditor could verify without asking a second question.

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

The review closed with no change. $29,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.

Case Study 2 · Structure rebuilt

Holding Structure Added, $31,000 Saved Annually — Director Facing Assessment, Hamilton

Client: A business owner with a director liability assessment  ·  Where: Hamilton, Ontario  ·  Engagement: 3 weeks, fixed fee

Annual saving$31,000
ReorganisationTax-neutral
StructureMatches operations

The situation — A business owner with a director liability assessment, Hamilton, Ontario

A business owner with a director liability assessment in Hamilton, Ontario was carrying a proposal letter with a 30-day response window and no supporting records assembled, and every option for fixing it ran through a reorganisation that had to be done without triggering tax.

What we did for A business owner with a director liability assessment, Hamilton, Ontario

Working with the client's lawyer, we traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly and prepared the elections, resolutions and valuations the structure needed to stand up.

The result — A business owner with a director liability assessment, Hamilton, Ontario

The structure now matches the business. Annual saving of $31,000, and the reorganisation itself was tax-neutral.

Case Study 3 · Cash and remittance control

Instalments Rebased, $160,000 Of Cash Returned To The Business — Importer Under Audit, Calgary

Client: An importer under a customs and GST audit  ·  Where: Calgary, Alberta  ·  Engagement: 4 weeks, fixed fee

Cash returned$160,000
Instalment basisCurrent year
ReviewedQuarterly

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

An importer under a customs and GST audit in Calgary, Alberta was paying instalments calculated on a prior year that no longer reflected the business. A waiver signed at the counter that kept an otherwise closed year open with no end date was tying up $160,000 of cash.

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

We rebased the instalments on the current-year estimate rather than the prior-year default, and brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action.

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

$160,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.

Case Study 4 · Missed incentive claimed

$132,000 Credit Claim Filed And Accepted Without Adjustment — Restaurant Under Net-Worth Audit, Moncton

Client: A restaurant under a net-worth audit  ·  Where: Moncton, New Brunswick  ·  Engagement: 9 weeks, fixed fee

Claim value$132,000
AcceptedWithout adjustment
RepeatableAnnually

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

A restaurant under a net-worth audit in Moncton, New Brunswick assumed the credits did not apply to a business its size. A waiver signed at the counter that kept an otherwise closed year open with no end date meant they had applied all along.

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

We identified the qualifying activity, built the documentation to support it, and 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 restaurant under a net-worth audit, Moncton, New Brunswick

$132,000 recovered. Because the eligibility analysis is on file, the same claim can be repeated each year with a fraction of the effort.

Case Study 5 · Objection and relief

Desk-Review Assessment Of $53,000 Vacated — Professional Under Lifestyle Audit, Regina

Client: A professional under a lifestyle audit  ·  Where: Regina, Saskatchewan  ·  Engagement: 7 weeks, fixed fee

Assessment vacated$53,000
Supporting recordsNow on file
AccountCleared

The situation — A professional under a lifestyle audit, Regina, Saskatchewan

A professional under a lifestyle audit in Regina, Saskatchewan was carrying $53,000 of penalties and interest arising from a confirmation letter left in a drawer until the appeal window had closed, much of it accumulated during a period the CRA itself had delayed.

What we did for A professional under a lifestyle audit, Regina, Saskatchewan

We requested the auditor’s working papers and report to see how the assessment had been built before answering any of it and framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.

The result — A professional under a lifestyle audit, Regina, Saskatchewan

The assessment was vacated. $53,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.

Case Study 6 · Planning that cut the bill

Remuneration Review Saved $58,000 Across Corporate And Personal Returns — Late-Objection Taxpayer, Surrey

Client: A taxpayer whose objection window has closed  ·  Where: Surrey, British Columbia  ·  Engagement: 3 weeks, fixed fee

Combined saving$58,000
ScopeCorporate + personal
Future yearsNo rework needed

The situation — A taxpayer whose objection window has closed, Surrey, British Columbia

Nothing was wrong at a taxpayer whose objection window has closed in Surrey, British Columbia — the filings were on time and accurate. What they were not was planned. An objection deadline that had passed with no extension applied for had never been reviewed.

What we did for A taxpayer whose objection window has closed, Surrey, British Columbia

We filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed, and ran the numbers across both the corporate and personal returns so the saving was real rather than deferred into someone else's hands.

The result — A taxpayer whose objection window has closed, Surrey, British Columbia

$58,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.

Reviewed for the 2025 tax year by Udit Gupta, Founder and Tax Accountant. 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.

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