SR&ED Audit Support Case Studies

6 worked SR&ED Audit Support 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 sr&ed audit support work, not a specific client's file.

Case Study 1 · Structure rebuilt

Holding Structure Added, $18,500 Saved Annually — Professional Under Lifestyle Audit, Mississauga

Client: A professional under a lifestyle audit  ·  Where: Mississauga, Ontario  ·  Engagement: 4 weeks, fixed fee

Annual saving$18,500
ReorganisationTax-neutral
StructureMatches operations

The situation — A professional under a lifestyle audit, Mississauga, Ontario

The structure at a professional under a lifestyle audit in Mississauga, Ontario needed fixing. The file was carrying six years of unfiled corporate and personal returns and an active collections file. Every option for fixing it ran through a reorganisation that had to be done without triggering tax.

What we did for A professional under a lifestyle audit, Mississauga, Ontario

We worked with the client's lawyer. Together, we brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. We also prepared the elections, resolutions and valuations the structure needed to stand up.

The result — A professional under a lifestyle audit, Mississauga, Ontario

The structure now matches the business. Annual saving of $18,500, and the reorganisation itself was tax-neutral.

Case Study 2 · Sale and succession

$775,000 Sheltered By The Lifetime Capital Gains Exemption — Corporation Under GST/HST Review, Halifax

Client: A corporation under a GST/HST review  ·  Where: Halifax, Nova Scotia  ·  Engagement: 7 weeks, fixed fee

Gain sheltered$775,000
ClosingOn schedule
Share qualificationMet

The situation — A corporation under a GST/HST review, Halifax, Nova Scotia

A corporation under a GST/HST review in Halifax, Nova Scotia had an offer on the table and 30 months to close. The shares did not qualify for the capital gains exemption. Passive assets sitting inside the operating company, disqualifying the shares was part of the reason.

What we did for A corporation under a GST/HST review, Halifax, Nova Scotia

We purified the corporation so the shares met the qualifying tests. We requested the auditor’s working papers and report to see how the assessment had been built before answering any of it. All of it was done well ahead of the closing date.

The result — A corporation under a GST/HST review, Halifax, Nova Scotia

The sale closed on schedule with $775,000 sheltered by the lifetime capital gains exemption across the shareholders.

Case Study 3 · CRA review defended

Audit Defence Closed In 6 Weeks, $98,000 Cleared — Contractor Facing Reassessment, Kitchener

Client: A contractor facing a proposed reassessment  ·  Where: Kitchener, Ontario  ·  Engagement: 6 weeks, fixed fee

Proposed tax cleared$98,000
Review duration6 weeks
OutcomeNo change

The situation — A contractor facing a proposed reassessment, Kitchener, Ontario

A contractor facing a proposed reassessment in Kitchener, Ontario was selected for review. A net-worth assessment built on unexplained deposits that were actually loan proceeds had shown up in the CRA's automated matching. The proposed adjustment on SR&ED audit support came to $98,000.

What we did for A contractor facing a proposed reassessment, Kitchener, Ontario

We kept the waiver narrowed to the issue actually under review and let the remaining years close on the normal reassessment period. Every figure in the response traced to a source record the auditor could verify without asking a second question.

The result — A contractor facing a proposed reassessment, Kitchener, Ontario

The review closed with no change. $98,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.

Case Study 4 · Planning that cut the bill

$67,000 Cut From The Annual Tax Bill — Taxpayer Relief Applicant, Kelowna

Client: A taxpayer applying for relief from penalties and interest  ·  Where: Kelowna, British Columbia  ·  Engagement: 8 weeks, fixed fee

First-year saving$67,000
RepeatsAnnually
Filing positionUnchanged in risk

The situation — A taxpayer applying for relief from penalties and interest, Kelowna, British Columbia

A taxpayer applying for relief from penalties and interest in Kelowna, British Columbia was compliant but paying more than it needed to. The prior year had been filed correctly. It still left an audit conducted over the phone, with nothing on file showing what had been provided or when on the table.

What we did for A taxpayer applying for relief from penalties and interest, Kelowna, British Columbia

We modelled the current position against the alternatives before changing anything. Then we filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely.

The result — A taxpayer applying for relief from penalties and interest, Kelowna, British Columbia

The change saved $67,000 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 5 · Records and systems rebuilt

Month-End Close Cut From 8 Weeks To 7 Days — Voluntary Disclosure Applicant, Edmonton

Client: A business owner considering a voluntary disclosure  ·  Where: Edmonton, Alberta  ·  Engagement: 5 weeks, fixed fee

Close time before8 weeks
Close time after7 days
Year-endReview, not rebuild

The situation — A business owner considering a voluntary disclosure, Edmonton, Alberta

The accounting file at a business owner considering a voluntary disclosure in Edmonton, Alberta had a weak foundation. It was built on a director liability assessment for a corporation that had already stopped operating. The year-end had taken 8 weeks each of the last three years.

What we did for A business owner considering a voluntary disclosure, Edmonton, Alberta

We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. We also moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.

The result — A business owner considering a voluntary disclosure, Edmonton, Alberta

The file reconciles. Month-end closes in 7 days instead of 8 weeks, and the year-end is a review rather than a reconstruction.

Case Study 6 · Objection and relief

Notice Of Objection Allowed In Full, $57,000 Reversed — Importer Under Audit, Saskatoon

Client: An importer under a customs and GST audit  ·  Where: Saskatoon, Saskatchewan  ·  Engagement: 10 weeks, fixed fee

Amount reversed$57,000
ObjectionAllowed in full
Account balanceNil

The situation — An importer under a customs and GST audit, Saskatoon, Saskatchewan

An importer under a customs and GST audit in Saskatoon, Saskatchewan had been reassessed for $57,000. 13 days were left on the objection deadline. The reassessment rested on a confirmation letter left in a drawer until the appeal window had closed.

What we did for An importer under a customs and GST audit, Saskatoon, Saskatchewan

We filed the objection inside the deadline with a complete submission rather than a placeholder. Alongside it, we assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn.

The result — An importer under a customs and GST audit, Saskatoon, Saskatchewan

The appeals officer allowed the objection in full. $57,000 was reversed and the account returned to a nil balance.

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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