6 worked Intercorporate Dividend 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 intercorporate dividend planning work, not a specific client's file.
Case Study 1 · Structure rebuilt
Corporate Structure Rebuilt For $43,000 Of Annual Savings — First-Profit Technology CCPC, 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 — A technology CCPC approaching its first profitable year, Brampton, Ontario
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 for A technology CCPC approaching its first profitable year, Brampton, Ontario
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 — A technology CCPC approaching its first profitable year, Brampton, Ontario
$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 — Holding and Operating Companies, Red Deer
Client: A holding company and its operating subsidiary · Where: Red Deer, Alberta · Engagement: 3 weeks, fixed fee
Arbitrary tax vacated$134,000
Years brought current7
Account statusCurrent
The situation — A holding company and its operating subsidiary, Red Deer, Alberta
7 years of unfiled returns had turned into notional assessments at a holding company and its operating subsidiary in Red Deer, Alberta, with passive investment income that had crossed the $50,000 grind threshold unnoticed underneath. Collections had already started.
What we did for A holding company and its operating subsidiary, Red Deer, Alberta
We carried the non-capital loss back against the two profitable years and recovered tax already paid instead of holding a carry-forward balance, then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.
The result — A holding company and its operating subsidiary, Red Deer, Alberta
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 — Import and Distribution Corporation, Moncton
Client: An import and distribution corporation · Where: Moncton, New Brunswick · Engagement: 4 weeks, fixed fee
Tax saved on closing$820,000
PriceAs agreed
Post-closing adjustmentsNone
The situation — An import and distribution corporation, Moncton, New Brunswick
An import and distribution corporation 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 for An import and distribution corporation, Moncton, New Brunswick
We cleaned up the historical file, reconstructed the capital dividend account from the underlying transactions and filed the subsection 83(2) election before the next distribution left the company, and prepared the due-diligence package the buyer's advisers actually asked for.
The result — An import and distribution corporation, Moncton, New Brunswick
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 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, Guelph, Ontario
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 a small business limit quietly shared across three associated corporations nobody had mapped.
What we did for A second-generation family manufacturer, Guelph, Ontario
We tested each activity against the eligibility criteria rather than the description on the invoice, then documented safe income before the inter-corporate dividend was paid, so subsection 55(2) had no room to recharacterise it as a gain.
The result — A second-generation family manufacturer, Guelph, Ontario
$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 — Corporation Holding Investments, Calgary
Client: An operating company holding surplus investments · Where: Calgary, Alberta · Engagement: 8 weeks, fixed fee
Reassessment reduced toNil
Tax protected$131,000
Prior filingsUndisturbed
The situation — An operating company holding surplus investments, Calgary, Alberta
A review notice arrived at an operating company holding surplus investments 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 for An operating company holding surplus investments, Calgary, Alberta
Rather than negotiate, we rebuilt the record. We reviewed each capital cost allowance pool and set the claim at the level that kept the small business deduction fully used rather than wasted and submitted a point-by-point response that answered each proposed adjustment with the document behind it.
The result — An operating company holding surplus investments, Calgary, Alberta
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 Consultancy, Edmonton
Client: An incorporated consultancy · Where: Edmonton, Alberta · Engagement: 9 weeks, fixed fee
Cash released$150,000
New registrationsComplete on day one
Compliance gapsNone
The situation — An incorporated consultancy, Edmonton, Alberta
Revenue at an incorporated consultancy in Edmonton, Alberta was up sharply and cash was tighter than ever. Underneath it sat a balance-due date the owner believed was the same as the filing date.
What we did for An incorporated consultancy, Edmonton, Alberta
We mapped the association rules across the group, allocated the business limit deliberately on Schedule 23, and corrected the prior year by adjustment request. Every new obligation — registration, remittance frequency, provincial filing — was set up before it was triggered, not after.
The result — An incorporated consultancy, Edmonton, Alberta
$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, 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.
