6 Section 85 Rollover Assistance 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 section 85 rollover assistance work, not a general example.
Case Study 1 · Backlog brought current
7 Years Filed, $97,000 Removed From The Assessed Balance — Incorporated Trades Business, Barrie
Client: An incorporated trades business · Where: Barrie, Ontario · Engagement: 4 weeks, fixed fee
Years filed7
Assessed balance removed$97,000
CollectionsStopped
The situation
An incorporated trades business in Barrie, Ontario had not filed for 7 years. The CRA had issued arbitrary assessments, and the business was carrying retained earnings building in the operating company with no plan for extracting them on top of a growing interest balance.
What we did
We started with the oldest year and worked forward so each year's closing balances fed the next. We rebuilt the instalment schedule off the current year rather than the prior year, ending the interest accrual, filing the years in sequence rather than all at once.
The result
Every year is now filed and assessed on actual figures. The notional assessments were vacated and $97,000 of the estimated balance came off, with a payment arrangement covering the rest.
Case Study 2 · Objection and relief
$127,000 Of Penalties And Interest Cancelled On Relief — Franchise Operator with Three, Regina
Client: A franchise operator with three locations · Where: Regina, Saskatchewan · Engagement: 6 weeks, fixed fee
Penalties and interest cancelled$127,000
Relief groundsAccepted
AssessmentAdjusted to filed position
The situation
An assessment of $127,000 landed at a franchise operator with three locations in Regina, Saskatchewan following a desk review. The auditor had not seen the records behind a balance-due date the owner believed was the same as the filing date.
What we did
We moved passive holdings into a separate structure so the operating company’s small business limit stopped grinding down, then set out the legislative basis for the position alongside the documents supporting it.
The result
$127,000 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.
Case Study 3 · Records and systems rebuilt
Month-End Close Cut From 11 Weeks To 7 Days — CCPC with Two Shareholders, Surrey
Client: A CCPC with two shareholders · Where: Surrey, British Columbia · Engagement: 6 weeks, fixed fee
Close time before11 weeks
Close time after7 days
Year-endReview, not rebuild
The situation
The accounting file at a CCPC with two shareholders in Surrey, British Columbia was built on a small business limit quietly shared across three associated corporations nobody had mapped. The year-end had taken 11 weeks each of the last three years.
What we did
We mapped the association rules across the group, allocated the business limit deliberately on Schedule 23, and corrected the prior year by adjustment request and moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.
The result
The file reconciles. Month-end closes in 7 days instead of 11 weeks, and the year-end is a review rather than a reconstruction.
Case Study 4 · Planning that cut the bill
Remuneration Review Saved $53,000 Across Corporate And Personal Returns — Corporately-Owned Rental Portfolio, Vancouver
Client: A corporately-owned rental portfolio · Where: Vancouver, British Columbia · Engagement: 11 weeks, fixed fee
Combined saving$53,000
ScopeCorporate + personal
Future yearsNo rework needed
The situation
Nothing was wrong at a corporately-owned rental portfolio in Vancouver, British Columbia — the filings were on time and accurate. What they were not was planned. Two corporations under common control filing as if each had its own $500,000 limit had never been reviewed.
What we did
We modelled salary against dividends across both the corporation and the shareholder’s personal return, then set the remuneration mix for the year, and ran the numbers across both the corporate and personal returns so the saving was real rather than deferred into someone else's hands.
The result
$53,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
Case Study 5 · CRA review defended
$19,000 Proposed Adjustment Withdrawn In Full — Professional Corporation, Kelowna
Client: A professional corporation · Where: Kelowna, British Columbia · Engagement: 10 weeks, fixed fee
Adjustment withdrawn$19,000
File closed in10 weeks
Penalties assessedNone
The situation
A professional corporation in Kelowna, British Columbia received a proposal letter opening a review of section 85 rollover assistance. The CRA had identified passive investment income that had crossed the $50,000 grind threshold unnoticed and proposed an adjustment of $19,000, with 30 days to respond.
What we did
We treated the response as an evidence exercise rather than an argument. We rebuilt the instalment schedule off the current year rather than the prior year, ending the interest accrual, then indexed every supporting document against the specific line the auditor had questioned.
The result
The proposed adjustment was withdrawn in full — all $19,000 of it. The file closed in 10 weeks with no change to the assessed amounts and no penalty.
Case Study 6 · Sale and succession
Intergenerational Transfer Completed With $550,000 Deferred — Import and Distribution Corporation, Kitchener
Client: An import and distribution corporation · Where: Kitchener, Ontario · Engagement: 6 weeks, fixed fee
Tax deferred$550,000
TransferCompleted
RecordsReview-ready
The situation
A generational transfer at an import and distribution corporation in Kitchener, Ontario had been discussed for years without a plan. Retained cash well above what the business needed to operate meant the transfer as contemplated would have been fully taxable.
What we did
We moved passive holdings into a separate structure so the operating company’s small business limit stopped grinding down, sequencing the steps so each one was complete and documented before the next depended on it.
The result
$550,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
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.
