6 worked Penalty and Interest Waiver Request 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 penalty and interest waiver request work, not a specific client's file.
Case Study 1 · Planning that cut the bill
$20,500 Cut From The Annual Tax Bill — Taxpayer Facing Collections, 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, Lethbridge, Alberta
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. It still left a waiver signed at the counter that kept an otherwise closed year open with no end date on the table.
What we did for A taxpayer with frozen bank accounts, Lethbridge, Alberta
We modelled the current position against the alternatives before changing anything. Then we kept the waiver narrowed to the issue actually under review and let the remaining years close on the normal reassessment period.
The result — A taxpayer with frozen bank accounts, Lethbridge, Alberta
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 — Taxpayer Relief Applicant, Toronto
Client: A taxpayer applying for relief from penalties and interest · Where: Toronto, Ontario · Engagement: 8 weeks, fixed fee
Cash returned$110,000
Instalment basisCurrent year
ReviewedQuarterly
The situation — A taxpayer applying for relief from penalties and interest, Toronto, Ontario
A taxpayer applying for relief from penalties and interest in Toronto, Ontario was paying instalments calculated on a prior year. That year no longer reflected the business. A director liability assessment for a corporation that had already stopped operating was tying up $110,000 of cash.
What we did for A taxpayer applying for relief from penalties and interest, Toronto, Ontario
We rebased the instalments on the current-year estimate rather than the prior-year default. Alongside that, we filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed.
The result — A taxpayer applying for relief from penalties and interest, Toronto, Ontario
$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 Lifestyle Audit, 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, Calgary, Alberta
A professional under a lifestyle audit in Calgary, Alberta could not answer basic questions about its own numbers. Six years of unfiled corporate and personal returns and an active collections file sat between the bank statements and the ledger.
What we did for A professional under a lifestyle audit, Calgary, Alberta
We requested the auditor’s working papers and report to see how the assessment had been built before answering any of it. We then documented the process so the work does not depend on any one person remembering how it was done.
The result — A professional under a lifestyle audit, Calgary, Alberta
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 — Voluntary Disclosure Applicant, Vancouver
Client: A business owner considering a voluntary disclosure · 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 — A business owner considering a voluntary disclosure, Vancouver, British Columbia
A business owner considering a voluntary disclosure in Vancouver, British Columbia was weeks away from the deadline for penalty and interest waiver request. Behind that sat a confirmation letter left in a drawer until the appeal window had closed. The exposure if the date slipped was around $141,000.
What we did for A business owner considering a voluntary disclosure, Vancouver, British Columbia
We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn. The filing went in complete rather than provisional, so there was no amended return to follow.
The result — A business owner considering a voluntary disclosure, Vancouver, British Columbia
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 GST/HST Review, 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, Mississauga, Ontario
A corporation under a GST/HST review in Mississauga, Ontario was carrying $105,000 of penalties and interest. The charges arose from an audit conducted over the phone, with nothing on file showing what had been provided or when. Much of that amount accumulated during a period the CRA itself had delayed.
What we did for A corporation under a GST/HST review, Mississauga, Ontario
We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. We framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A corporation under a GST/HST review, Mississauga, Ontario
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 — Importer Under Audit, Edmonton
Client: An importer under a customs and GST audit · Where: Edmonton, Alberta · Engagement: 3 weeks, fixed fee
Saving per year$34,000
DocumentationComplete
Transfer basisRollover
The situation — An importer under a customs and GST audit, Edmonton, Alberta
The structure at an importer under a customs and GST audit in Edmonton, 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 An importer under a customs and GST audit, Edmonton, Alberta
We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result — An importer under a customs and GST audit, Edmonton, Alberta
$34,000 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.
