Customs Excise and Commodity Tax Coordination Case Studies
6 worked Customs Excise and Commodity Tax Coordination 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 customs excise and commodity tax coordination work, not a specific client's file.
Case Study 1 · Planning that cut the bill
$34,500 Cut From The Annual Tax Bill — Mixed-Use Landlord, Saskatoon
Client: A residential landlord also renting commercial space · Where: Saskatoon, Saskatchewan · Engagement: 7 weeks, fixed fee
First-year saving$34,500
RepeatsAnnually
Filing positionUnchanged in risk
The situation — A residential landlord also renting commercial space, Saskatoon, Saskatchewan
A residential landlord also renting commercial space in Saskatoon, Saskatchewan was compliant but paying more than it needed to. The prior year had been filed correctly. It still left HST charged at the home-province rate on sales into four different provinces on the table.
What we did for A residential landlord also renting commercial space, Saskatoon, Saskatchewan
We modelled the current position against the alternatives before changing anything. Then we rebuilt the sales ledger by customer province and applied the correct place-of-supply rate to each stream. We filed corrected returns before the CRA opened a review.
The result — A residential landlord also renting commercial space, Saskatoon, Saskatchewan
The change saved $34,500 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 · Structure rebuilt
Reorganisation Completed Tax-Deferred, $22,000 Saved Each Year — Interprovincial Marketing Agency, Hamilton
Client: A marketing agency billing outside its home province · Where: Hamilton, Ontario · Engagement: 8 weeks, fixed fee
Annual saving$22,000
Tax on reorganisationDeferred
Elections filedOn time
The situation — A marketing agency billing outside its home province, Hamilton, Ontario
A marketing agency billing outside its home province in Hamilton, Ontario had outgrown the structure it started with. Input tax credits claimed on the exempt side of a mixed-supply business was the immediate problem. The longer-term one was that the structure blocked the next step.
What we did for A marketing agency billing outside its home province, Hamilton, Ontario
We mapped the current structure and modelled the target. Then we filed the section 156 election for the related registrants, so supplies between them stopped carrying tax that served no purpose but cash-flow drag. The tax-deferred elections were filed on time and the supporting valuations documented.
The result — A marketing agency billing outside its home province, Hamilton, Ontario
The reorganisation completed without triggering tax, and the new structure saves approximately $22,000 a year while removing the exposure the old one carried.
Case Study 3 · Scaling without breaking
Scaled To 64 Staff With $136,000 Of Working Capital Freed — Exempt-Supply Clinic, Edmonton
Client: A health clinic making exempt supplies · Where: Edmonton, Alberta · Engagement: 8 weeks, fixed fee
Headcount reached64
Working capital freed$136,000
Missed deadlinesZero
The situation — A health clinic making exempt supplies, Edmonton, Alberta
A health clinic making exempt supplies in Edmonton, Alberta was growing fast, with headcount reaching 64 in eighteen months. The back office had not kept up. A sales tax account filed annually while the CRA had moved the business to quarterly was the first thing to break.
What we did for A health clinic making exempt supplies, Edmonton, Alberta
We backdated the registration to the date the business stopped being a small supplier, remitted the tax owing, and applied for relief on the penalty portion. We built the compliance calendar for the size the business was becoming rather than the size it had been.
The result — A health clinic making exempt supplies, Edmonton, Alberta
The business reached 64 staff with no missed remittance and no late filing. $136,000 of working capital was freed in the process.
Case Study 4 · Objection and relief
Notice Of Objection Allowed In Full, $60,000 Reversed — Restaurant Group, Calgary
Client: A restaurant group · Where: Calgary, Alberta · Engagement: 11 weeks, fixed fee
Amount reversed$60,000
ObjectionAllowed in full
Account balanceNil
The situation — A restaurant group, Calgary, Alberta
A restaurant group in Calgary, Alberta had been reassessed for $60,000. 18 days were left on the objection deadline. The reassessment rested on a commercial property purchase closed on the assumption no tax applied because the vendor was not registered.
What we did for A restaurant group, Calgary, Alberta
We filed the objection inside the deadline with a complete submission rather than a placeholder. Alongside it, we self-assessed the tax on the real property acquisition in the correct reporting period and claimed the offsetting input tax credit in the same return.
The result — A restaurant group, Calgary, Alberta
The appeals officer allowed the objection in full. $60,000 was reversed and the account returned to a nil balance.
Case Study 5 · CRA review defended
$142,000 Proposed Adjustment Withdrawn In Full — Multi-Province Online Retailer, Guelph
The situation — A multi-province online retailer, Guelph, Ontario
A multi-province online retailer in Guelph, Ontario received a proposal letter opening a review of customs excise and commodity tax coordination. The CRA had identified a registration threshold crossed nine months before anyone registered. It proposed an adjustment of $142,000, with 30 days to respond.
What we did for A multi-province online retailer, Guelph, Ontario
We treated the response as an evidence exercise rather than an argument. We set a defensible input tax credit allocation between taxable and exempt supplies and documented the method for future filings. We then indexed every supporting document against the specific line the auditor had questioned.
The result — A multi-province online retailer, Guelph, Ontario
The proposed adjustment was withdrawn in full — all $142,000 of it. The file closed in 10 weeks with no change to the assessed amounts and no penalty.
Client: A manufacturer exporting to the US · Where: Moncton, New Brunswick · Engagement: 4 weeks, fixed fee
Penalty cancelled$60,000
Relief applicationGranted
ReturnAccepted as filed
The situation — A manufacturer exporting to the US, Moncton, New Brunswick
A manufacturer exporting to the US in Moncton, New Brunswick had already missed one deadline and was about to miss a second. Behind it sat export sales zero-rated with no shipping documentation behind them. A penalty of $60,000 was accruing.
What we did for A manufacturer exporting to the US, Moncton, New Brunswick
We split the work into what had to happen before the deadline and what could follow it. Then we brought the nil and missing periods current so the account was clean before the refund claim was filed.
The result — A manufacturer exporting to the US, Moncton, New Brunswick
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $60,000 of the penalty already assessed on the earlier year.
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.
