6 worked Personal Tax Objection 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 personal tax objection work, not a specific client's file.
Case Study 1 · Scaling without breaking
Second-Province Expansion Handled, $52,000 Of Cash Released — Employer Under Payroll Review, Regina
Client: A company facing a payroll trust examination · Where: Regina, Saskatchewan · Engagement: 3 weeks, fixed fee
Cash released$52,000
New registrationsComplete on day one
Compliance gapsNone
The situation — A company facing a payroll trust examination, Regina, Saskatchewan
Revenue at a company facing a payroll trust examination in Regina, Saskatchewan was up sharply and cash was tighter than ever. Underneath it sat an objection deadline that had passed with no extension applied for.
What we did for A company facing a payroll trust examination, Regina, Saskatchewan
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. Every new obligation was set up before it was triggered, not after. That covered registration, remittance frequency and provincial filing.
The result — A company facing a payroll trust examination, Regina, Saskatchewan
$52,000 of cash was released from the working capital cycle. The expansion completed with every registration and filing obligation covered from day one.
Case Study 2 · Missed incentive claimed
$30,500 In Credits Claimed That Prior Filings Had Missed — Importer Under Audit, Winnipeg
Client: An importer under a customs and GST audit · Where: Winnipeg, Manitoba · Engagement: 5 weeks, fixed fee
Credits claimed$30,500
Years adjusted5
Review outcomeNo adjustment
The situation — An importer under a customs and GST audit, Winnipeg, Manitoba
An importer under a customs and GST audit in Winnipeg, Manitoba had been filing for 5 years. In that time, the incentives its activity qualified for were never claimed. Behind that sat a net-worth assessment built on unexplained deposits that were actually loan proceeds.
What we did for An importer under a customs and GST audit, Winnipeg, Manitoba
We tested each activity against the eligibility criteria rather than the description on the invoice. Then we filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely.
The result — An importer under a customs and GST audit, Winnipeg, Manitoba
$30,500 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 3 · Backlog brought current
7 Years Filed, $102,000 Removed From The Assessed Balance — Assessed Shareholder, Guelph
Client: A shareholder assessed on a taxable benefit · Where: Guelph, Ontario · Engagement: 10 weeks, fixed fee
Years filed7
Assessed balance removed$102,000
CollectionsStopped
The situation — A shareholder assessed on a taxable benefit, Guelph, Ontario
A shareholder assessed on a taxable benefit in Guelph, Ontario had not filed for 7 years. The CRA had issued arbitrary assessments. The business was carrying an audit conducted over the phone, with nothing on file showing what had been provided or when. That came on top of a growing interest balance.
What we did for A shareholder assessed on a taxable benefit, Guelph, Ontario
We started with the oldest year and worked forward so each year's closing balances fed the next. We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. We filed the years in sequence rather than all at once.
The result — A shareholder assessed on a taxable benefit, Guelph, Ontario
Every year is now filed and assessed on actual figures. The notional assessments were vacated and $102,000 of the estimated balance came off, with a payment arrangement covering the rest.
Case Study 4 · Objection and relief
$36,500 Of Penalties And Interest Cancelled On Relief — Contractor Facing Reassessment, Kitchener
Client: A contractor facing a proposed reassessment · Where: Kitchener, Ontario · Engagement: 9 weeks, fixed fee
Penalties and interest cancelled$36,500
Relief groundsAccepted
AssessmentAdjusted to filed position
The situation — A contractor facing a proposed reassessment, Kitchener, Ontario
An assessment of $36,500 landed at a contractor facing a proposed reassessment in Kitchener, Ontario following a desk review. It turned on a director liability assessment for a corporation that had already stopped operating. The auditor had not seen the records behind it.
What we did for A contractor facing a proposed reassessment, Kitchener, Ontario
We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. We then set out the legislative basis for the position alongside the documents supporting it.
The result — A contractor facing a proposed reassessment, Kitchener, Ontario
$36,500 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.
Case Study 5 · Structure rebuilt
Holding Structure Added, $52,000 Saved Annually — Director Facing Assessment, Hamilton
Client: A business owner with a director liability assessment · Where: Hamilton, Ontario · Engagement: 4 weeks, fixed fee
Annual saving$52,000
ReorganisationTax-neutral
StructureMatches operations
The situation — A business owner with a director liability assessment, Hamilton, Ontario
The structure at a business owner with a director liability assessment in Hamilton, Ontario needed fixing. The file was carrying a proposal letter with a 30-day response window and no supporting records assembled. Every option for fixing it ran through a reorganisation that had to be done without triggering tax.
What we did for A business owner with a director liability assessment, Hamilton, Ontario
We worked with the client's lawyer. Together, 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 prepared the elections, resolutions and valuations the structure needed to stand up.
The result — A business owner with a director liability assessment, Hamilton, Ontario
The structure now matches the business. Annual saving of $52,000, and the reorganisation itself was tax-neutral.
Client: A taxpayer with frozen bank accounts · Where: Lethbridge, Alberta · Engagement: 9 weeks, fixed fee
Penalty cancelled$124,000
Relief applicationGranted
ReturnAccepted as filed
The situation — A taxpayer with frozen bank accounts, Lethbridge, Alberta
A taxpayer with frozen bank accounts in Lethbridge, Alberta had already missed one deadline and was about to miss a second. Behind it sat a waiver signed at the counter that kept an otherwise closed year open with no end date. A penalty of $124,000 was accruing.
What we did for A taxpayer with frozen bank accounts, Lethbridge, Alberta
We split the work into what had to happen before the deadline and what could follow it. 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 taxpayer with frozen bank accounts, Lethbridge, Alberta
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $124,000 of the penalty already assessed on the earlier year.
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.
