6 worked Estate Tax Planning 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 estate tax planning work, not a specific client's file.
Case Study 1 · CRA review defended
$82,000 Reassessment Reduced To Nil On Review — Trust Nearing Deemed Disposition, Regina
Client: A trust approaching its deemed disposition date · Where: Regina, Saskatchewan · Engagement: 3 weeks, fixed fee
Reassessment reduced toNil
Tax protected$82,000
Prior filingsUndisturbed
The situation — A trust approaching its deemed disposition date, Regina, Saskatchewan
A review notice arrived at a trust approaching its deemed disposition date in Regina, Saskatchewan covering estate tax planning for two tax years. The auditor's working position was an adjustment of $82,000, driven by a farm transfer completed without using the intergenerational rollover.
What we did for A trust approaching its deemed disposition date, Regina, Saskatchewan
Rather than negotiate, we rebuilt the record. We used the spousal rollover for the assets going to the surviving spouse and reported only the dispositions that actually had to be reported and submitted a point-by-point response that answered each proposed adjustment with the document behind it.
The result — A trust approaching its deemed disposition date, Regina, Saskatchewan
The auditor accepted the documented position and closed the review without adjustment, protecting $82,000 and leaving the prior filings undisturbed.
Case Study 2 · Missed incentive claimed
$28,000 In Credits Claimed That Prior Filings Had Missed — Newly Reporting Trustee, Winnipeg
Client: A trustee facing the expanded reporting rules · Where: Winnipeg, Manitoba · Engagement: 4 weeks, fixed fee
Credits claimed$28,000
Years adjusted3
Review outcomeNo adjustment
The situation — A trustee facing the expanded reporting rules, Winnipeg, Manitoba
A trustee facing the expanded reporting rules in Winnipeg, Manitoba had been filing for 3 years without ever claiming the incentives its activity qualified for. Behind that sat years of surplus cash sitting in the operating company, putting the asset tests for the exemption out of reach.
What we did for A trustee facing the expanded reporting rules, Winnipeg, Manitoba
We tested each activity against the eligibility criteria rather than the description on the invoice, then filed the outstanding T3 returns with full beneficial-ownership schedules and secured relief on the late-filing penalty.
The result — A trustee facing the expanded reporting rules, Winnipeg, Manitoba
$28,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 3 · Sale and succession
$865,000 Sheltered By The Lifetime Capital Gains Exemption — Intergenerational Transfer Corporation, Guelph
Client: A corporation planning an intergenerational transfer · Where: Guelph, Ontario · Engagement: 7 weeks, fixed fee
Gain sheltered$865,000
ClosingOn schedule
Share qualificationMet
The situation — A corporation planning an intergenerational transfer, Guelph, Ontario
A corporation planning an intergenerational transfer in Guelph, Ontario had an offer on the table and 10 months to close. The shares did not qualify for the capital gains exemption, and a shareholder loan balance that would have been picked up as income on closing was part of the reason.
What we did for A corporation planning an intergenerational transfer, Guelph, Ontario
We purified the corporation so the shares met the qualifying tests, then purified the corporation across two full years, so the shares met the asset tests by the time the sale closed well ahead of the closing date.
The result — A corporation planning an intergenerational transfer, Guelph, Ontario
The sale closed on schedule with $865,000 sheltered by the lifetime capital gains exemption across the shareholders.
Case Study 4 · Backlog brought current
5 Years Filed, $106,000 Removed From The Assessed Balance — Cottage Trust Family, Kitchener
Client: A family with a cottage held in trust · Where: Kitchener, Ontario · Engagement: 8 weeks, fixed fee
Years filed5
Assessed balance removed$106,000
CollectionsStopped
The situation — A family with a cottage held in trust, Kitchener, Ontario
A family with a cottage held in trust in Kitchener, Ontario had not filed for 5 years. The CRA had issued arbitrary assessments, and the business was carrying a graduated rate estate designation missed on the first return, defaulting the estate to top-rate taxation on top of a growing interest balance.
What we did for A family with a cottage held in trust, Kitchener, Ontario
We started with the oldest year and worked forward so each year's closing balances fed the next. We filed the separate rights-or-things return alongside the final T1, claiming a second set of personal credits, filing the years in sequence rather than all at once.
The result — A family with a cottage held in trust, Kitchener, Ontario
Every year is now filed and assessed on actual figures. The notional assessments were vacated and $106,000 of the estimated balance came off, with a payment arrangement covering the rest.
Case Study 5 · Structure rebuilt
Reorganisation Completed Tax-Deferred, $71,000 Saved Each Year — Spousal Trust, Hamilton
Client: A spousal trust following a death · Where: Hamilton, Ontario · Engagement: 8 weeks, fixed fee
Annual saving$71,000
Tax on reorganisationDeferred
Elections filedOn time
The situation — A spousal trust following a death, Hamilton, Ontario
A spousal trust following a death in Hamilton, Ontario had outgrown the structure it started with. An estate distributing to adult children with no provision made for the deemed disposition on the final return was the immediate problem; the longer-term one was that the structure blocked the next step.
What we did for A spousal trust following a death, Hamilton, Ontario
We mapped the current structure, modelled the target, and allocated trust income to the beneficiaries within the trust’s own year and supported each allocation with a T3 slip — with the tax-deferred elections filed on time and the supporting valuations documented.
The result — A spousal trust following a death, Hamilton, Ontario
The reorganisation completed without triggering tax, and the new structure saves approximately $71,000 a year while removing the exposure the old one carried.
Case Study 6 · Objection and relief
$37,000 Of Penalties And Interest Cancelled On Relief — Estate with Private Shares, Lethbridge
Client: An estate holding a private corporation · Where: Lethbridge, Alberta · Engagement: 5 weeks, fixed fee
Penalties and interest cancelled$37,000
Relief groundsAccepted
AssessmentAdjusted to filed position
The situation — An estate holding a private corporation, Lethbridge, Alberta
An assessment of $37,000 landed at an estate holding a private corporation in Lethbridge, Alberta following a desk review. The auditor had not seen the records behind a will naming an executor with no authority to keep the business running while the estate was administered.
What we did for An estate holding a private corporation, Lethbridge, Alberta
We made the graduated rate estate designation and re-filed, moving the estate off top-marginal-rate taxation for its first three years, then set out the legislative basis for the position alongside the documents supporting it.
The result — An estate holding a private corporation, Lethbridge, Alberta
$37,000 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.
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.
