ROE Correction and Reissue Case Studies

6 worked ROE Correction and Reissue 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 roe correction and reissue work, not a specific client's file.

Case Study 1 · Structure rebuilt

Reorganisation Completed Tax-Deferred, $67,000 Saved Each Year — Company-Vehicle Employer, Vancouver

Client: An employer providing company vehicles. Where: Vancouver, British Columbia. Engagement: 7 weeks, fixed fee.

Annual saving$67,000
Tax on reorganisationDeferred
Elections filedOn time

Case 1: the situation

An employer providing company vehicles in Vancouver, British Columbia had outgrown the structure it started with. Remittances still going out monthly after the business had moved to the accelerated threshold was the immediate problem. The longer-term one was that the structure blocked the next step.

Case 1: what we did

We mapped the current structure and modelled the target. Then we moved the account to the correct remitter frequency and caught up the arrears. We filed a taxpayer relief request that cancelled the bulk of the penalty. The tax-deferred elections were filed on time and the supporting valuations documented.

Case 1: the result

The reorganisation completed without triggering tax, and the new structure saves approximately $67,000 a year while removing the exposure the old one carried.

Case Study 2 · Deadline rescue

9-Week Turnaround Beat The Deadline And Saved $127,000 — Higher-Frequency Remitter, Lethbridge

Client: An employer whose remittance frequency moved up a threshold. Where: Lethbridge, Alberta. Engagement: 9 weeks, fixed fee.

Late-filing penalty avoided$127,000
Filed with16 days to spare
Next yearPapers ready

Case 2: the situation

An employer whose remittance frequency moved up a threshold in Lethbridge, Alberta was weeks away from the deadline for ROE correction and reissue. Behind that sat a director facing a personal assessment for unremitted source deductions. The exposure if the date slipped was around $127,000.

Case 2: what we did

We filed the outstanding slips and summary and requested relief on the per-slip penalty with the reasons documented in writing. The filing went in complete rather than provisional, so there was no amended return to follow.

Case 2: the result

Filed with 16 days to spare. $127,000 in late-filing penalties avoided, and the working papers are ready for the following year.

Case Study 3 · Cash and remittance control

Remittance Schedule Corrected, $82,000 Refunded — Contractor-Paid Clinic, Barrie

Client: A clinic paying its associates as contractors. Where: Barrie, Ontario. Engagement: 9 weeks, fixed fee.

Overpayment refunded$82,000
Late remittances sinceZero
ScheduleAutomated

Case 3: the situation

Remittances at a clinic paying its associates as contractors in Barrie, Ontario were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat long-term contractors who met every test for employment.

Case 3: what we did

We paid the accrued bonus inside the 180-day window and kept the deduction in the year it was accrued. Then we moved the remittance dates into a scheduled process rather than a monthly decision.

Case 3: the result

Penalties stopped from the following remittance onwards, and $82,000 of overpaid instalments was refunded.

Case Study 4 · Scaling without breaking

Scaled To 82 Staff With $53,000 Of Working Capital Freed — Multi-Province Driver Fleet, Victoria

Client: A logistics operator with drivers in three provinces. Where: Victoria, British Columbia. Engagement: 7 weeks, fixed fee.

Headcount reached82
Working capital freed$53,000
Missed deadlinesZero

Case 4: the situation

A logistics operator with drivers in three provinces in Victoria, British Columbia was growing fast, with headcount reaching 82 in eighteen months. The back office had not kept up. A bonus accrued to bring the year-end tax bill down and still unpaid more than a year later was the first thing to break.

Case 4: what we did

We reconstructed vehicle logbooks, calculated the standby charge and operating benefit properly, and amended the affected T4s. We built the compliance calendar for the size the business was becoming rather than the size it had been.

Case 4: the result

The business reached 82 staff with no missed remittance and no late filing. $53,000 of working capital was freed in the process.

Case Study 5 · Missed incentive claimed

Incentive Review Recovered $42,000 Across 7 Open Years — Dental Practice, Regina

Client: A dental practice. Where: Regina, Saskatchewan. Engagement: 5 weeks, fixed fee.

Recovered$42,000
Open years claimed7
Ongoing trackingIn place

Case 5: the situation

An incentive review at a dental practice in Regina, Saskatchewan started from a simple question: what has never been claimed? The answer ran to 7 years. It was driven by remittances still going out monthly after the business had moved to the accelerated threshold.

Case 5: what we did

We reviewed each contractor against the CRA’s control and integration tests and converted those who met the employment tests. We priced the transition before it was forced by a ruling. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.

Case 5: the result

The credits produced $42,000 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 6 · Backlog brought current

$25,000 Of Arbitrary Assessments Vacated After 5 Years — Seasonal Landscaping Employer, London

Client: A landscaping company with seasonal staff. Where: London, Ontario. Engagement: 8 weeks, fixed fee.

Arbitrary tax vacated$25,000
Years brought current5
Account statusCurrent

Case 6: the situation

5 years of unfiled returns had turned into notional assessments at a landscaping company with seasonal staff in London, Ontario. Underneath lay an employee over-deducted for CPP and EI after being moved between two related payroll accounts mid-year. Collections had already started.

Case 6: what we did

We wrote each pay code against its income tax, CPP and EI treatment. That way, a new benefit could not reach the payroll without a decision on how it was withheld. We then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.

Case 6: the result

All 5 years were accepted as filed. $25,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 5 years.

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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