Nominee Director Services Case Studies

6 worked Nominee Director Services 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 nominee director services work, not a specific client's file.

Case Study 1 · Planning that cut the bill

$19,000 Saved By Correcting What Prior Filings Had Missed — Federal Registry Filer, Red Deer

Client: A federal corporation filing its registry annual return. Where: Red Deer, Alberta. Engagement: 6 weeks, fixed fee.

Saving identified$19,000
RecurringYes
Positions documentedAll

Case 1: the situation

A federal corporation filing its registry annual return in Red Deer, Alberta asked for a second opinion on nominee director services. That followed three years of rising tax. The review found a register of individuals with significant control that had never been opened, let alone updated.

Case 1: what we did

We built the comparison first: current structure against two alternatives. Then we filed the change of registered office and the director changes, so registry correspondence reached someone who read it.

Case 1: the result

First-year saving of $19,000, with the same benefit recurring. Every position taken is documented and supported in the file.

Case Study 2 · Objection and relief

Notice Of Objection Allowed In Full, $15,500 Reversed — Newly Formed Corporation, Calgary

Client: A corporation choosing its first fiscal year-end. Where: Calgary, Alberta. Engagement: 8 weeks, fixed fee.

Amount reversed$15,500
ObjectionAllowed in full
Account balanceNil

Case 2: the situation

A corporation choosing its first fiscal year-end in Calgary, Alberta had been reassessed for $15,500. 15 days were left on the objection deadline. The reassessment rested on dividends paid for three years with no directors’ resolutions behind them.

Case 2: what we did

We filed the objection inside the deadline with a complete submission rather than a placeholder. Alongside it, we tested each intended dividend recipient against the excluded-amount tests before any dividend was declared, and recorded which test was being relied on.

Case 2: the result

The appeals officer allowed the objection in full. $15,500 was reversed and the account returned to a nil balance.

Case Study 3 · Missed incentive claimed

Incentive Review Recovered $131,000 Across 6 Open Years — Incorporating Contractor, Saskatoon

Client: A contractor incorporating for liability reasons. Where: Saskatoon, Saskatchewan. Engagement: 6 weeks, fixed fee.

Recovered$131,000
Open years claimed6
Ongoing trackingIn place

Case 3: the situation

An incentive review at a contractor incorporating for liability reasons in Saskatoon, Saskatchewan started from a simple question: what has never been claimed? The answer ran to 6 years. It was driven by GST/HST collected for eight months before the RT account was ever opened.

Case 3: what we did

We reconstructed the minute book with resolutions for each historical dividend and share transaction. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.

Case 3: the result

The credits produced $131,000 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 4 · Cash and remittance control

Remittance Schedule Corrected, $35,500 Refunded — Family Business Adding Shares, Moncton

Client: A family business adding a second class of shares. Where: Moncton, New Brunswick. Engagement: 11 weeks, fixed fee.

Overpayment refunded$35,500
Late remittances sinceZero
ScheduleAutomated

Case 4: the situation

Remittances at a family business adding a second class of shares in Moncton, New Brunswick were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat a single class of common shares that made income splitting impossible.

Case 4: what we did

We revived the corporation, filed the outstanding annual returns, and set a compliance calendar covering both the corporate registry and the CRA. Then we moved the remittance dates into a scheduled process rather than a monthly decision.

Case 4: the result

Penalties stopped from the following remittance onwards, and $35,500 of overpaid instalments was refunded.

Case Study 5 · Structure rebuilt

Corporate Structure Rebuilt For $44,000 Of Annual Savings — Federally Incorporating Seller, Edmonton

Client: An e-commerce seller incorporating federally. Where: Edmonton, Alberta. Engagement: 5 weeks, fixed fee.

Saving per year$44,000
DocumentationComplete
Transfer basisRollover

Case 5: the situation

The structure at an e-commerce seller incorporating federally in Edmonton, Alberta dated from years earlier. It had been set up for a business that no longer existed. A corporation dissolved administratively for missed annual returns while still operating had become expensive.

Case 5: what we did

We separated the corporate registry deadlines from the CRA deadlines on one calendar, with a named person responsible for each. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.

Case 5: the result

$44,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.

Case Study 6 · CRA review defended

$59,000 Proposed Adjustment Withdrawn In Full — Holding Structure Founder, Brampton

Client: A founder setting up a holding structure. Where: Brampton, Ontario. Engagement: 8 weeks, fixed fee.

Adjustment withdrawn$59,000
File closed in8 weeks
Penalties assessedNone

Case 6: the situation

A founder setting up a holding structure in Brampton, Ontario received a proposal letter opening a review of nominee director services. The CRA had identified GST/HST collected for eight months before the RT account was ever opened. It proposed an adjustment of $59,000, with 30 days to respond.

Case 6: what we did

We treated the response as an evidence exercise rather than an argument. We opened the register of individuals with significant control and put its review on the same annual cycle as the corporate annual return. We then indexed every supporting document against the specific line the auditor had questioned.

Case 6: the result

The proposed adjustment was withdrawn in full — all $59,000 of it. The file closed in 8 weeks with no change to the assessed amounts and no penalty.

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)

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