Intercorporate Dividend Planning Case Studies

6 Intercorporate Dividend Planning tax and accounting engagements in full — what the client came to us with, what we did, and what it was worth. Each one is specific to intercorporate dividend planning work, not a general example.

Case Study 1 · Structure rebuilt

Corporate Structure Rebuilt For $43,000 Of Annual Savings — Technology CCPC Approaching Its, Brampton

Client: A technology CCPC approaching its first profitable year  ·  Where: Brampton, Ontario  ·  Engagement: 8 weeks, fixed fee

Saving per year$43,000
DocumentationComplete
Transfer basisRollover

The situation

The structure at a technology CCPC approaching its first profitable year in Brampton, Ontario had been set up years earlier for a business that no longer existed, and two corporations under common control filing as if each had its own $500,000 limit had become expensive.

What we did

We modelled salary against dividends across both the corporation and the shareholder’s personal return, then set the remuneration mix for the year. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.

The result

$43,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.

Case Study 2 · Backlog brought current

$134,000 Of Arbitrary Assessments Vacated After 7 Years — Import and Distribution Corporation, Red Deer

Client: An import and distribution corporation  ·  Where: Red Deer, Alberta  ·  Engagement: 3 weeks, fixed fee

Arbitrary tax vacated$134,000
Years brought current7
Account statusCurrent

The situation

7 years of unfiled returns had turned into notional assessments at an import and distribution corporation in Red Deer, Alberta, with a balance-due date the owner believed was the same as the filing date underneath. Collections had already started.

What we did

We moved passive holdings into a separate structure so the operating company’s small business limit stopped grinding down, then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.

The result

All 7 years were accepted as filed. $134,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 7 years.

Case Study 3 · Sale and succession

Share Sale Restructured, $820,000 Less Tax On Closing — Holding Company and Its, Moncton

Client: A holding company and its operating subsidiary  ·  Where: Moncton, New Brunswick  ·  Engagement: 4 weeks, fixed fee

Tax saved on closing$820,000
PriceAs agreed
Post-closing adjustmentsNone

The situation

A holding company and its operating subsidiary in Moncton, New Brunswick was preparing to sell. Due diligence surfaced a single shareholder holding every share, with no room to multiply the exemption, which would have reduced the price or killed the deal outright.

What we did

We cleaned up the historical file, mapped the association rules across the group, allocated the business limit deliberately on Schedule 23, and corrected the prior year by adjustment request, and prepared the due-diligence package the buyer's advisers actually asked for.

The result

The deal closed at the agreed price. $820,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.

Case Study 4 · Missed incentive claimed

$72,000 In Credits Claimed That Prior Filings Had Missed — Second-Generation Family Manufacturer, Guelph

Client: A second-generation family manufacturer  ·  Where: Guelph, Ontario  ·  Engagement: 5 weeks, fixed fee

Credits claimed$72,000
Years adjusted6
Review outcomeNo adjustment

The situation

A second-generation family manufacturer in Guelph, Ontario had been filing for 6 years without ever claiming the incentives its activity qualified for. Behind that sat retained earnings building in the operating company with no plan for extracting them.

What we did

We tested each activity against the eligibility criteria rather than the description on the invoice, then rebuilt the instalment schedule off the current year rather than the prior year, ending the interest accrual.

The result

$72,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.

Case Study 5 · CRA review defended

$131,000 Reassessment Reduced To Nil On Review — Incorporated Consultancy, Calgary

Client: An incorporated consultancy  ·  Where: Calgary, Alberta  ·  Engagement: 8 weeks, fixed fee

Reassessment reduced toNil
Tax protected$131,000
Prior filingsUndisturbed

The situation

A review notice arrived at an incorporated consultancy in Calgary, Alberta covering intercorporate dividend planning for two tax years. The auditor's working position was an adjustment of $131,000, driven by retained earnings building in the operating company with no plan for extracting them.

What we did

Rather than negotiate, we rebuilt the record. We modelled salary against dividends across both the corporation and the shareholder’s personal return, then set the remuneration mix for the year and submitted a point-by-point response that answered each proposed adjustment with the document behind it.

The result

The auditor accepted the documented position and closed the review without adjustment, protecting $131,000 and leaving the prior filings undisturbed.

Case Study 6 · Scaling without breaking

Second-Province Expansion Handled, $150,000 Of Cash Released — Incorporated Trades Business, Edmonton

Client: An incorporated trades business  ·  Where: Edmonton, Alberta  ·  Engagement: 9 weeks, fixed fee

Cash released$150,000
New registrationsComplete on day one
Compliance gapsNone

The situation

Revenue at an incorporated trades business in Edmonton, Alberta was up sharply and cash was tighter than ever. Underneath it sat two corporations under common control filing as if each had its own $500,000 limit.

What we did

We moved passive holdings into a separate structure so the operating company’s small business limit stopped grinding down. Every new obligation — registration, remittance frequency, provincial filing — was set up before it was triggered, not after.

The result

$150,000 of cash was released from the working capital cycle, and the expansion completed with every registration and filing obligation covered from day one.

Reviewed for the 2025 tax year by Udit Gupta, Certified Tax Accountant. Figures describe representative engagements of this type; outcomes depend on your own facts. Client names and identifying details are omitted for confidentiality.

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