6 worked Mandatory Disclosure Reporting 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 mandatory disclosure reporting work, not a specific client's file.
Case Study 1 · CRA review defended
$108,000 Proposed Adjustment Withdrawn In Full — Director Facing Assessment, Toronto
Client: A business owner with a director liability assessment · Where: Toronto, Ontario · Engagement: 10 weeks, fixed fee
Adjustment withdrawn$108,000
File closed in10 weeks
Penalties assessedNone
The situation — A business owner with a director liability assessment, Toronto, Ontario
A business owner with a director liability assessment in Toronto, Ontario received a proposal letter opening a review of mandatory disclosure reporting. The CRA had identified an audit conducted over the phone, with nothing on file showing what had been provided or when and proposed an adjustment of $108,000, with 30 days to respond.
What we did for A business owner with a director liability assessment, Toronto, Ontario
We treated the response as an evidence exercise rather than an argument. We filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed, then indexed every supporting document against the specific line the auditor had questioned.
The result — A business owner with a director liability assessment, Toronto, Ontario
The proposed adjustment was withdrawn in full — all $108,000 of it. The file closed in 10 weeks with no change to the assessed amounts and no penalty.
Case Study 2 · Missed incentive claimed
$17,500 In Credits Claimed That Prior Filings Had Missed — Restaurant Under Net-Worth Audit, Hamilton
Client: A restaurant under a net-worth audit · Where: Hamilton, Ontario · Engagement: 4 weeks, fixed fee
Credits claimed$17,500
Years adjusted7
Review outcomeNo adjustment
The situation — A restaurant under a net-worth audit, Hamilton, Ontario
A restaurant under a net-worth audit in Hamilton, Ontario had been filing for 7 years without ever claiming the incentives its activity qualified for. Behind that sat six years of unfiled corporate and personal returns and an active collections file.
What we did for A restaurant under a net-worth audit, Hamilton, Ontario
We tested each activity against the eligibility criteria rather than the description on the invoice, then filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely.
The result — A restaurant under a net-worth audit, Hamilton, Ontario
$17,500 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 3 · Sale and succession
Intergenerational Transfer Completed With $890,000 Deferred — Late-Objection Taxpayer, Regina
Client: A taxpayer whose objection window has closed · Where: Regina, Saskatchewan · Engagement: 6 weeks, fixed fee
Tax deferred$890,000
TransferCompleted
RecordsReview-ready
The situation — A taxpayer whose objection window has closed, Regina, Saskatchewan
A generational transfer at a taxpayer whose objection window has closed in Regina, Saskatchewan had been discussed for years without a plan. Passive assets sitting inside the operating company, disqualifying the shares meant the transfer as contemplated would have been fully taxable.
What we did for A taxpayer whose objection window has closed, Regina, Saskatchewan
We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn, sequencing the steps so each one was complete and documented before the next depended on it.
The result — A taxpayer whose objection window has closed, Regina, Saskatchewan
$890,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
Case Study 4 · Backlog brought current
Collections Halted And $56,000 Cut From A 7-Year Backlog — Employer Under Payroll Review, Kelowna
Client: A company facing a payroll trust examination · Where: Kelowna, British Columbia · Engagement: 10 weeks, fixed fee
Balance reduced by$56,000
Backlog cleared7 years
CollectionsHalted
The situation — A company facing a payroll trust examination, Kelowna, British Columbia
By the time a company facing a payroll trust examination in Kelowna, British Columbia called, 7 years were outstanding and the CRA had assessed on estimates. Underneath it sat a confirmation letter left in a drawer until the appeal window had closed.
What we did for A company facing a payroll trust examination, Kelowna, British Columbia
We reconstructed the records year by year and kept the waiver narrowed to the issue actually under review and let the remaining years close on the normal reassessment period. Each filing replaced an arbitrary assessment with a real one.
The result — A company facing a payroll trust examination, Kelowna, British Columbia
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $56,000, and a relief application addressed part of the accumulated interest.
Case Study 5 · Structure rebuilt
Reorganisation Completed Tax-Deferred, $43,000 Saved Each Year — Long-Term Non-Filer, Edmonton
Client: A taxpayer with eight years of unfiled returns · Where: Edmonton, Alberta · Engagement: 5 weeks, fixed fee
Annual saving$43,000
Tax on reorganisationDeferred
Elections filedOn time
The situation — A taxpayer with eight years of unfiled returns, Edmonton, Alberta
A taxpayer with eight years of unfiled returns in Edmonton, Alberta had outgrown the structure it started with. A net-worth assessment built on unexplained deposits that were actually loan proceeds was the immediate problem; the longer-term one was that the structure blocked the next step.
What we did for A taxpayer with eight years of unfiled returns, Edmonton, Alberta
We mapped the current structure, modelled the target, and traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly — with the tax-deferred elections filed on time and the supporting valuations documented.
The result — A taxpayer with eight years of unfiled returns, Edmonton, Alberta
The reorganisation completed without triggering tax, and the new structure saves approximately $43,000 a year while removing the exposure the old one carried.
Case Study 6 · Objection and relief
Desk-Review Assessment Of $35,000 Vacated — Assessed Shareholder, London
Client: A shareholder assessed on a taxable benefit · Where: London, Ontario · Engagement: 7 weeks, fixed fee
Assessment vacated$35,000
Supporting recordsNow on file
AccountCleared
The situation — A shareholder assessed on a taxable benefit, London, Ontario
A shareholder assessed on a taxable benefit in London, Ontario was carrying $35,000 of penalties and interest arising from a waiver signed at the counter that kept an otherwise closed year open with no end date, much of it accumulated during a period the CRA itself had delayed.
What we did for A shareholder assessed on a taxable benefit, London, Ontario
We requested the auditor’s working papers and report to see how the assessment had been built before answering any of it and framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A shareholder assessed on a taxable benefit, London, Ontario
The assessment was vacated. $35,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
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.
