Notifiable Transaction Review Case Studies

6 worked Notifiable Transaction Review 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 notifiable transaction review work, not a specific client's file.

Case Study 1 · Planning that cut the bill

$12,500 Cut From The Annual Tax Bill — Voluntary Disclosure Applicant, Calgary

Client: A business owner considering a voluntary disclosure  ·  Where: Calgary, Alberta  ·  Engagement: 4 weeks, fixed fee

First-year saving$12,500
RepeatsAnnually
Filing positionUnchanged in risk

The situation — A business owner considering a voluntary disclosure, Calgary, Alberta

A business owner considering a voluntary disclosure in Calgary, Alberta was compliant but paying more than it needed to. The prior year had been filed correctly. It still left a confirmation letter left in a drawer until the appeal window had closed on the table.

What we did for A business owner considering a voluntary disclosure, Calgary, Alberta

We modelled the current position against the alternatives before changing anything. Then we requested the auditor’s working papers and report to see how the assessment had been built before answering any of it.

The result — A business owner considering a voluntary disclosure, Calgary, Alberta

The change saved $12,500 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 2 · Sale and succession

$810,000 Sheltered By The Lifetime Capital Gains Exemption — Late-Objection Taxpayer, Regina

Client: A taxpayer whose objection window has closed  ·  Where: Regina, Saskatchewan  ·  Engagement: 8 weeks, fixed fee

Gain sheltered$810,000
ClosingOn schedule
Share qualificationMet

The situation — A taxpayer whose objection window has closed, Regina, Saskatchewan

A taxpayer whose objection window has closed in Regina, Saskatchewan had an offer on the table and 20 months to close. The shares did not qualify for the capital gains exemption. Passive assets sitting inside the operating company, disqualifying the shares was part of the reason.

What we did for A taxpayer whose objection window has closed, Regina, Saskatchewan

We purified the corporation so the shares met the qualifying tests. 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. All of it was done well ahead of the closing date.

The result — A taxpayer whose objection window has closed, Regina, Saskatchewan

The sale closed on schedule with $810,000 sheltered by the lifetime capital gains exemption across the shareholders.

Case Study 3 · Deadline rescue

Filed On Time From A Standing Start, $98,000 Penalty Avoided — Importer Under Audit, Mississauga

Client: An importer under a customs and GST audit  ·  Where: Mississauga, Ontario  ·  Engagement: 5 weeks, fixed fee

Penalty avoided$98,000
Turnaround5 weeks
FiledOn time

The situation — An importer under a customs and GST audit, Mississauga, Ontario

An importer under a customs and GST audit in Mississauga, Ontario came to us 5 weeks before its filing deadline. The file came with a waiver signed at the counter that kept an otherwise closed year open with no end date. A late filing would have triggered a penalty of roughly $98,000 before interest.

What we did for An importer under a customs and GST audit, Mississauga, Ontario

We worked backwards from the deadline. We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. We prioritised the items that actually gated the filing and deferred everything that did not.

The result — An importer under a customs and GST audit, Mississauga, Ontario

The return was filed on time and complete. The $98,000 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.

Case Study 4 · Scaling without breaking

Scaled To 61 Staff With $50,000 Of Working Capital Freed — Family Business Under Review, Red Deer

Client: A family business under a related-party review  ·  Where: Red Deer, Alberta  ·  Engagement: 4 weeks, fixed fee

Headcount reached61
Working capital freed$50,000
Missed deadlinesZero

The situation — A family business under a related-party review, Red Deer, Alberta

A family business under a related-party review in Red Deer, Alberta was growing fast, with headcount reaching 61 in eighteen months. The back office had not kept up. A proposal letter with a 30-day response window and no supporting records assembled was the first thing to break.

What we did for A family business under a related-party review, Red Deer, Alberta

We filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed. We built the compliance calendar for the size the business was becoming rather than the size it had been.

The result — A family business under a related-party review, Red Deer, Alberta

The business reached 61 staff with no missed remittance and no late filing. $50,000 of working capital was freed in the process.

Case Study 5 · Backlog brought current

6 Years Filed, $22,000 Removed From The Assessed Balance — Taxpayer Facing Collections, Ottawa

Client: A taxpayer with frozen bank accounts  ·  Where: Ottawa, Ontario  ·  Engagement: 10 weeks, fixed fee

Years filed6
Assessed balance removed$22,000
CollectionsStopped

The situation — A taxpayer with frozen bank accounts, Ottawa, Ontario

A taxpayer with frozen bank accounts in Ottawa, Ontario had not filed for 6 years. The CRA had issued arbitrary assessments. The business was carrying a director liability assessment for a corporation that had already stopped operating. That came on top of a growing interest balance.

What we did for A taxpayer with frozen bank accounts, Ottawa, Ontario

We started with the oldest year and worked forward so each year's closing balances fed the next. We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely. We filed the years in sequence rather than all at once.

The result — A taxpayer with frozen bank accounts, Ottawa, Ontario

Every year is now filed and assessed on actual figures. The notional assessments were vacated and $22,000 of the estimated balance came off, with a payment arrangement covering the rest.

Case Study 6 · Records and systems rebuilt

Month-End Close Cut From 11 Weeks To 7 Days — Employer Under Payroll Review, Windsor

Client: A company facing a payroll trust examination  ·  Where: Windsor, Ontario  ·  Engagement: 8 weeks, fixed fee

Close time before11 weeks
Close time after7 days
Year-endReview, not rebuild

The situation — A company facing a payroll trust examination, Windsor, Ontario

The accounting file at a company facing a payroll trust examination in Windsor, Ontario had a weak foundation. It was built on an audit conducted over the phone, with nothing on file showing what had been provided or when. The year-end had taken 11 weeks each of the last three years.

What we did for A company facing a payroll trust examination, Windsor, Ontario

We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn. We also moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.

The result — A company facing a payroll trust examination, Windsor, Ontario

The file reconciles. Month-end closes in 7 days instead of 11 weeks, and the year-end is a review rather than a reconstruction.

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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