Penalty and Interest Waiver Request Case Studies

6 Penalty and Interest Waiver Request tax and accounting engagements in full — what the client came to us with, what we did, and what it was worth. Each one is specific to penalty and interest waiver request work, not a general example.

Case Study 1 · Planning that cut the bill

$20,500 Cut From The Annual Tax Bill — Taxpayer with Frozen Bank, Lethbridge

Client: A taxpayer with frozen bank accounts  ·  Where: Lethbridge, Alberta  ·  Engagement: 5 weeks, fixed fee

First-year saving$20,500
RepeatsAnnually
Filing positionUnchanged in risk

The situation

A taxpayer with frozen bank accounts in Lethbridge, Alberta was compliant but paying more than it needed to. The prior year had been filed correctly and still left a director liability assessment for a corporation that had already stopped operating on the table.

What we did

We modelled the current position against the alternatives before changing anything, then brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action.

The result

The change saved $20,500 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 · Cash and remittance control

Instalments Rebased, $110,000 Of Cash Returned To The Business — Company Facing a Payroll, Toronto

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

Cash returned$110,000
Instalment basisCurrent year
ReviewedQuarterly

The situation

A company facing a payroll trust examination in Toronto, Ontario was paying instalments calculated on a prior year that no longer reflected the business. A proposal letter with a 30-day response window and no supporting records assembled was tying up $110,000 of cash.

What we did

We rebased the instalments on the current-year estimate rather than the prior-year default, and assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn.

The result

$110,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.

Case Study 3 · Records and systems rebuilt

Books Rebuilt From Source, $4,000 In Unclaimed Input Tax Found — Professional Under a Lifestyle, Calgary

Client: A professional under a lifestyle audit  ·  Where: Calgary, Alberta  ·  Engagement: 6 weeks, fixed fee

Unclaimed tax found$4,000
Records rebuilt9 months
ProcessDocumented

The situation

A professional under a lifestyle audit in Calgary, Alberta could not answer basic questions about its own numbers, because a net-worth assessment built on unexplained deposits that were actually loan proceeds sat between the bank statements and the ledger.

What we did

We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely, then documented the process so the work does not depend on any one person remembering how it was done.

The result

Records rebuilt and reconciled, $4,000 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.

Case Study 4 · Deadline rescue

5-Week Turnaround Beat The Deadline And Saved $141,000 — Business Owner with a, Vancouver

Client: A business owner with a director liability assessment  ·  Where: Vancouver, British Columbia  ·  Engagement: 5 weeks, fixed fee

Late-filing penalty avoided$141,000
Filed with16 days to spare
Next yearPapers ready

The situation

With the deadline for penalty and interest waiver request weeks away, a business owner with a director liability assessment in Vancouver, British Columbia was carrying an objection deadline that had passed with no extension applied for. The exposure if the date slipped was around $141,000.

What we did

We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. The filing went in complete rather than provisional, so there was no amended return to follow.

The result

Filed with 16 days to spare. $141,000 in late-filing penalties avoided, and the working papers are ready for the following year.

Case Study 5 · Objection and relief

Desk-Review Assessment Of $105,000 Vacated — Corporation Under a GST/HST, Mississauga

Client: A corporation under a GST/HST review  ·  Where: Mississauga, Ontario  ·  Engagement: 9 weeks, fixed fee

Assessment vacated$105,000
Supporting recordsNow on file
AccountCleared

The situation

A corporation under a GST/HST review in Mississauga, Ontario was carrying $105,000 of penalties and interest arising from six years of unfiled corporate and personal returns and an active collections file, much of it accumulated during a period the CRA itself had delayed.

What we did

We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action and framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.

The result

The assessment was vacated. $105,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.

Case Study 6 · Structure rebuilt

Corporate Structure Rebuilt For $34,000 Of Annual Savings — Taxpayer with Eight Years, Edmonton

Client: A taxpayer with eight years of unfiled returns  ·  Where: Edmonton, Alberta  ·  Engagement: 3 weeks, fixed fee

Saving per year$34,000
DocumentationComplete
Transfer basisRollover

The situation

The structure at a taxpayer with eight years of unfiled returns in Edmonton, Alberta had been set up years earlier for a business that no longer existed, and a director liability assessment for a corporation that had already stopped operating had become expensive.

What we did

We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.

The result

$34,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.

Reviewed for the 2025 tax year by Udit Gupta, Certified Tax Accountant. Figures describe representative engagements of this type; outcomes depend on your own facts. Client names and identifying details are omitted for confidentiality.

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