6 worked Tax Court Accounting 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 tax court accounting support work, not a specific client's file.
Case Study 1 · Backlog brought current
6 Years Filed, $46,000 Removed From The Assessed Balance — Importer Under Audit, Brampton
Client: An importer under a customs and GST audit · Where: Brampton, Ontario · Engagement: 4 weeks, fixed fee
Years filed6
Assessed balance removed$46,000
CollectionsStopped
The situation — An importer under a customs and GST audit, Brampton, Ontario
An importer under a customs and GST audit in Brampton, Ontario had not filed for 6 years. The CRA had issued arbitrary assessments. The business was carrying a director liability assessment for a corporation that had already stopped operating. That came on top of a growing interest balance.
What we did for An importer under a customs and GST audit, Brampton, Ontario
We started with the oldest year and worked forward so each year's closing balances fed the next. We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely. We filed the years in sequence rather than all at once.
The result — An importer under a customs and GST audit, Brampton, Ontario
Every year is now filed and assessed on actual figures. The notional assessments were vacated and $46,000 of the estimated balance came off, with a payment arrangement covering the rest.
Case Study 2 · Cash and remittance control
Instalments Rebased, $149,000 Of Cash Returned To The Business — Late-Objection Taxpayer, Ottawa
Client: A taxpayer whose objection window has closed · Where: Ottawa, Ontario · Engagement: 10 weeks, fixed fee
Cash returned$149,000
Instalment basisCurrent year
ReviewedQuarterly
The situation — A taxpayer whose objection window has closed, Ottawa, Ontario
A taxpayer whose objection window has closed in Ottawa, Ontario was paying instalments calculated on a prior year. That year no longer reflected the business. An objection deadline that had passed with no extension applied for was tying up $149,000 of cash.
What we did for A taxpayer whose objection window has closed, Ottawa, 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 whose objection window has closed, Ottawa, Ontario
$149,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.
Case Study 3 · Sale and succession
Share Sale Restructured, $690,000 Less Tax On Closing — Voluntary Disclosure Applicant, Kelowna
Client: A business owner considering a voluntary disclosure · Where: Kelowna, British Columbia · Engagement: 10 weeks, fixed fee
Tax saved on closing$690,000
PriceAs agreed
Post-closing adjustmentsNone
The situation — A business owner considering a voluntary disclosure, Kelowna, British Columbia
A business owner considering a voluntary disclosure in Kelowna, British Columbia was preparing to sell. Due diligence surfaced a single shareholder holding every share, with no room to multiply the exemption. That would have reduced the price or killed the deal outright.
What we did for A business owner considering a voluntary disclosure, Kelowna, British Columbia
We cleaned up the historical file. We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. Then we prepared the due-diligence package the buyer's advisers actually asked for.
The result — A business owner considering a voluntary disclosure, Kelowna, British Columbia
The deal closed at the agreed price. $690,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.
Case Study 4 · Records and systems rebuilt
22 Months Reconciled And $19,500 Of Input Tax Recovered — Assessed Shareholder, Regina
Client: A shareholder assessed on a taxable benefit · Where: Regina, Saskatchewan · Engagement: 8 weeks, fixed fee
Months reconciled22
Input tax recovered$19,500
Close time7 days
The situation — A shareholder assessed on a taxable benefit, Regina, Saskatchewan
Nothing reconciled at a shareholder assessed on a taxable benefit in Regina, Saskatchewan. Every filing started with 22 months of cleanup. The file was carrying an audit conducted over the phone, with nothing on file showing what had been provided or when.
What we did for A shareholder assessed on a taxable benefit, Regina, Saskatchewan
We rebuilt from source rather than correcting on top of the existing file. 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. Then we set the routine that keeps it clean.
The result — A shareholder assessed on a taxable benefit, Regina, Saskatchewan
22 months reconciled to the bank. The close now takes 7 days, and $19,500 of previously unclaimable input tax was recovered in the process.
Case Study 5 · Missed incentive claimed
Incentive Review Recovered $80,000 Across 5 Open Years — Taxpayer Relief Applicant, Winnipeg
Client: A taxpayer applying for relief from penalties and interest · Where: Winnipeg, Manitoba · Engagement: 8 weeks, fixed fee
Recovered$80,000
Open years claimed5
Ongoing trackingIn place
The situation — A taxpayer applying for relief from penalties and interest, Winnipeg, Manitoba
An incentive review at a taxpayer applying for relief from penalties and interest in Winnipeg, Manitoba started from a simple question: what has never been claimed? The answer ran to 5 years. It was driven by a director liability assessment for a corporation that had already stopped operating.
What we did for A taxpayer applying for relief from penalties and interest, Winnipeg, Manitoba
We requested the auditor’s working papers and report to see how the assessment had been built before answering any of it. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result — A taxpayer applying for relief from penalties and interest, Winnipeg, Manitoba
The credits produced $80,000 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 · Deadline rescue
6-Week Turnaround Beat The Deadline And Saved $48,000 — Restaurant Under Net-Worth Audit, Guelph
Client: A restaurant under a net-worth audit · Where: Guelph, Ontario · Engagement: 6 weeks, fixed fee
Late-filing penalty avoided$48,000
Filed with19 days to spare
Next yearPapers ready
The situation — A restaurant under a net-worth audit, Guelph, Ontario
A restaurant under a net-worth audit in Guelph, Ontario was weeks away from the deadline for tax court accounting support. Behind that sat a proposal letter with a 30-day response window and no supporting records assembled. The exposure if the date slipped was around $48,000.
What we did for A restaurant under a net-worth audit, Guelph, Ontario
We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. The filing went in complete rather than provisional, so there was no amended return to follow.
The result — A restaurant under a net-worth audit, Guelph, Ontario
Filed with 19 days to spare. $48,000 in late-filing penalties avoided, and the working papers are ready for the following 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.
