Late-Filed Election Relief Case Studies

6 worked Late-Filed Election Relief 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 late-filed election relief work, not a specific client's file.

Case Study 1 · CRA review defended

Audit Defence Closed In 3 Weeks, $79,000 Cleared — Voluntary Disclosure Applicant, Kitchener

Client: A business owner considering a voluntary disclosure  ·  Where: Kitchener, Ontario  ·  Engagement: 3 weeks, fixed fee

Proposed tax cleared$79,000
Review duration3 weeks
OutcomeNo change

The situation — A business owner considering a voluntary disclosure, Kitchener, Ontario

A business owner considering a voluntary disclosure in Kitchener, Ontario was selected for review. A waiver signed at the counter that kept an otherwise closed year open with no end date had shown up in the CRA's automated matching. The proposed adjustment on late-filed election relief came to $79,000.

What we did for A business owner considering a voluntary disclosure, Kitchener, Ontario

We kept the waiver narrowed to the issue actually under review and let the remaining years close on the normal reassessment period. Every figure in the response traced to a source record the auditor could verify without asking a second question.

The result — A business owner considering a voluntary disclosure, Kitchener, Ontario

The review closed with no change. $79,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.

Case Study 2 · Backlog brought current

4 Years Filed, $101,000 Removed From The Assessed Balance — Taxpayer Relief Applicant, Barrie

Client: A taxpayer applying for relief from penalties and interest  ·  Where: Barrie, Ontario  ·  Engagement: 10 weeks, fixed fee

Years filed4
Assessed balance removed$101,000
CollectionsStopped

The situation — A taxpayer applying for relief from penalties and interest, Barrie, Ontario

A taxpayer applying for relief from penalties and interest in Barrie, Ontario had not filed for 4 years. The CRA had issued arbitrary assessments. The business was carrying a proposal letter with a 30-day response window and no supporting records assembled. That came on top of a growing interest balance.

What we did for A taxpayer applying for relief from penalties and interest, Barrie, Ontario

We started with the oldest year and worked forward so each year's closing balances fed the next. We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. We filed the years in sequence rather than all at once.

The result — A taxpayer applying for relief from penalties and interest, Barrie, Ontario

Every year is now filed and assessed on actual figures. The notional assessments were vacated and $101,000 of the estimated balance came off, with a payment arrangement covering the rest.

Case Study 3 · Deadline rescue

11-Week Turnaround Beat The Deadline And Saved $12,000 — Contractor Facing Reassessment, Calgary

Client: A contractor facing a proposed reassessment  ·  Where: Calgary, Alberta  ·  Engagement: 11 weeks, fixed fee

Late-filing penalty avoided$12,000
Filed with19 days to spare
Next yearPapers ready

The situation — A contractor facing a proposed reassessment, Calgary, Alberta

A contractor facing a proposed reassessment in Calgary, Alberta was weeks away from the deadline for late-filed election relief. Behind that sat a director liability assessment for a corporation that had already stopped operating. The exposure if the date slipped was around $12,000.

What we did for A contractor facing a proposed reassessment, Calgary, Alberta

We requested the auditor’s working papers and report to see how the assessment had been built before answering any of it. The filing went in complete rather than provisional, so there was no amended return to follow.

The result — A contractor facing a proposed reassessment, Calgary, Alberta

Filed with 19 days to spare. $12,000 in late-filing penalties avoided, and the working papers are ready for the following year.

Case Study 4 · Planning that cut the bill

$58,000 Cut From The Annual Tax Bill — Corporation Under GST/HST Review, Winnipeg

Client: A corporation under a GST/HST review  ·  Where: Winnipeg, Manitoba  ·  Engagement: 10 weeks, fixed fee

First-year saving$58,000
RepeatsAnnually
Filing positionUnchanged in risk

The situation — A corporation under a GST/HST review, Winnipeg, Manitoba

A corporation under a GST/HST review in Winnipeg, Manitoba was compliant but paying more than it needed to. The prior year had been filed correctly. It still left an audit conducted over the phone, with nothing on file showing what had been provided or when on the table.

What we did for A corporation under a GST/HST review, Winnipeg, Manitoba

We modelled the current position against the alternatives before changing anything. Then we answered each query in writing with an indexed document package, so the file showed exactly what the auditor had received and on what date.

The result — A corporation under a GST/HST review, Winnipeg, Manitoba

The change saved $58,000 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 5 · Missed incentive claimed

Incentive Review Recovered $34,500 Across 3 Open Years — Professional Under Lifestyle Audit, London

Client: A professional under a lifestyle audit  ·  Where: London, Ontario  ·  Engagement: 11 weeks, fixed fee

Recovered$34,500
Open years claimed3
Ongoing trackingIn place

The situation — A professional under a lifestyle audit, London, Ontario

An incentive review at a professional under a lifestyle audit in London, Ontario started from a simple question: what has never been claimed? The answer ran to 3 years. It was driven by a waiver signed at the counter that kept an otherwise closed year open with no end date.

What we did for A professional under a lifestyle audit, London, Ontario

We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.

The result — A professional under a lifestyle audit, London, Ontario

The credits produced $34,500 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 6 · Structure rebuilt

Corporate Structure Rebuilt For $50,000 Of Annual Savings — Taxpayer Facing Collections, Red Deer

Client: A taxpayer with frozen bank accounts  ·  Where: Red Deer, Alberta  ·  Engagement: 9 weeks, fixed fee

Saving per year$50,000
DocumentationComplete
Transfer basisRollover

The situation — A taxpayer with frozen bank accounts, Red Deer, Alberta

The structure at a taxpayer with frozen bank accounts in Red Deer, Alberta dated from years earlier. It had been set up for a business that no longer existed. An objection deadline that had passed with no extension applied for had become expensive.

What we did for A taxpayer with frozen bank accounts, Red Deer, Alberta

We filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.

The result — A taxpayer with frozen bank accounts, Red Deer, Alberta

$50,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.

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 — Businesses · Income Tax Act (Justice Laws Website)

← Back to Late-Filed Election Relief  ·  All case studies

Free 15 Min Consultation for Businesses

Ready to get started with Late-Filed Election Relief tax support?

Talk to a professional tax accountant about your situation. No obligation, and you only pay once the work is complete and you have approved it.

  • Tax accountant led team
  • Fixed fees, no hourly billing
  • Pay only after you approve

+1 (416) 619-0068 381 Front St W, Toronto, ON M5V 3R8

Our Partners Are Alumni of the World's Top Accounting and Tax Institutions

Chartered Professional Accountants Canada AICPA — American Institute of Certified Public Accountants Institute of Chartered Accountants of India Malaysian Institute of Accountants