GST/HST Account Closure Case Studies

6 worked GST/HST Account Closure 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 gst/hst account closure work, not a specific client's file.

Case Study 1 · Structure rebuilt

Holding Structure Added, $59,000 Saved Annually — US-Bound Exporter, Edmonton

Client: A manufacturer exporting to the US  ·  Where: Edmonton, Alberta  ·  Engagement: 4 weeks, fixed fee

Annual saving$59,000
ReorganisationTax-neutral
StructureMatches operations

The situation — A manufacturer exporting to the US, Edmonton, Alberta

The structure at a manufacturer exporting to the US in Edmonton, Alberta needed fixing. The file was carrying input tax credits claimed on the exempt side of a mixed-supply business. Every option for fixing it ran through a reorganisation that had to be done without triggering tax.

What we did for A manufacturer exporting to the US, Edmonton, Alberta

We worked with the client's lawyer. Together, we set a defensible input tax credit allocation between taxable and exempt supplies and documented the method for future filings. We also prepared the elections, resolutions and valuations the structure needed to stand up.

The result — A manufacturer exporting to the US, Edmonton, Alberta

The structure now matches the business. Annual saving of $59,000, and the reorganisation itself was tax-neutral.

Case Study 2 · Missed incentive claimed

Incentive Review Recovered $62,000 Across 6 Open Years — Mixed-Use Landlord, Calgary

Client: A residential landlord also renting commercial space  ·  Where: Calgary, Alberta  ·  Engagement: 6 weeks, fixed fee

Recovered$62,000
Open years claimed6
Ongoing trackingIn place

The situation — A residential landlord also renting commercial space, Calgary, Alberta

An incentive review at a residential landlord also renting commercial space in Calgary, Alberta started from a simple question: what has never been claimed? The answer ran to 6 years. It was driven by input tax credits claimed on the exempt side of a mixed-supply business.

What we did for A residential landlord also renting commercial space, Calgary, Alberta

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. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.

The result — A residential landlord also renting commercial space, Calgary, Alberta

The credits produced $62,000 across the open years. The tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.

Case Study 3 · Planning that cut the bill

$72,000 Cut From The Annual Tax Bill — Exempt-Supply Clinic, Guelph

Client: A health clinic making exempt supplies  ·  Where: Guelph, Ontario  ·  Engagement: 11 weeks, fixed fee

First-year saving$72,000
RepeatsAnnually
Filing positionUnchanged in risk

The situation — A health clinic making exempt supplies, Guelph, Ontario

A health clinic making exempt supplies in Guelph, Ontario 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 health clinic making exempt supplies, Guelph, Ontario

We modelled the current position against the alternatives before changing anything. Then we brought the nil and missing periods current so the account was clean before the refund claim was filed.

The result — A health clinic making exempt supplies, Guelph, Ontario

The change saved $72,000 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 4 · Deadline rescue

Filed On Time From A Standing Start, $97,000 Penalty Avoided — Multi-Province Online Retailer, Moncton

Client: A multi-province online retailer  ·  Where: Moncton, New Brunswick  ·  Engagement: 8 weeks, fixed fee

Penalty avoided$97,000
Turnaround8 weeks
FiledOn time

The situation — A multi-province online retailer, Moncton, New Brunswick

A multi-province online retailer in Moncton, New Brunswick came to us 8 weeks before its filing deadline. The file came with nil periods left unfiled, which held up the refund on the one period that mattered. A late filing would have triggered a penalty of roughly $97,000 before interest.

What we did for A multi-province online retailer, Moncton, New Brunswick

We worked backwards from the deadline. 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. We prioritised the items that actually gated the filing and deferred everything that did not.

The result — A multi-province online retailer, Moncton, New Brunswick

The return was filed on time and complete. The $97,000 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.

Case Study 5 · Backlog brought current

Collections Halted And $138,000 Cut From A 5-Year Backlog — Cross-Border SaaS Company, Red Deer

Client: A SaaS company with Canadian and US customers  ·  Where: Red Deer, Alberta  ·  Engagement: 10 weeks, fixed fee

Balance reduced by$138,000
Backlog cleared5 years
CollectionsHalted

The situation — A SaaS company with Canadian and US customers, Red Deer, Alberta

By the time a SaaS company with Canadian and US customers in Red Deer, Alberta called, 5 years were outstanding. The CRA had assessed on estimates. Underneath it sat a commercial property purchase closed on the assumption no tax applied because the vendor was not registered.

What we did for A SaaS company with Canadian and US customers, Red Deer, Alberta

We reconstructed the records year by year. We assembled the export documentation, restored zero-rating on the qualifying sales, and reduced the proposed assessment. Each filing replaced an arbitrary assessment with a real one.

The result — A SaaS company with Canadian and US customers, Red Deer, Alberta

The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $138,000, and a relief application addressed part of the accumulated interest.

Case Study 6 · CRA review defended

$88,000 Reassessment Reduced To Nil On Review — Interprovincial Marketing Agency, Brampton

Client: A marketing agency billing outside its home province  ·  Where: Brampton, Ontario  ·  Engagement: 3 weeks, fixed fee

Reassessment reduced toNil
Tax protected$88,000
Prior filingsUndisturbed

The situation — A marketing agency billing outside its home province, Brampton, Ontario

A review notice arrived at a marketing agency billing outside its home province in Brampton, Ontario, covering GST/HST account closure for two tax years. The auditor's working position was an adjustment of $88,000. It was driven by management fees between two related registrants carrying tax that only ever went out and came back.

What we did for A marketing agency billing outside its home province, Brampton, Ontario

Rather than negotiate, we rebuilt the record. 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. We then submitted a point-by-point response that answered each proposed adjustment with the document behind it.

The result — A marketing agency billing outside its home province, Brampton, Ontario

The auditor accepted the documented position and closed the review without adjustment, protecting $88,000 and leaving the prior filings undisturbed.

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 — GST/HST for businesses · CRA — GST/HST rates by province · Income Tax Act (Justice Laws Website)

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