6 worked Tax Lien Review 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 lien review work, not a specific client's file.
Case Study 1 · Missed incentive claimed
$89,000 In Credits Claimed That Prior Filings Had Missed — Voluntary Disclosure Applicant, Halifax
Client: A business owner considering a voluntary disclosure · Where: Halifax, Nova Scotia · Engagement: 8 weeks, fixed fee
Credits claimed$89,000
Years adjusted7
Review outcomeNo adjustment
The situation — A business owner considering a voluntary disclosure, Halifax, Nova Scotia
A business owner considering a voluntary disclosure in Halifax, Nova Scotia had been filing for 7 years. In that time, the incentives its activity qualified for were never claimed. Behind that sat a director liability assessment for a corporation that had already stopped operating.
What we did for A business owner considering a voluntary disclosure, Halifax, Nova Scotia
We tested each activity against the eligibility criteria rather than the description on the invoice. 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 business owner considering a voluntary disclosure, Halifax, Nova Scotia
$89,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 2 · Scaling without breaking
Growth Handled Without A Missed Filing, $155,000 Freed — Long-Term Non-Filer, Edmonton
Client: A taxpayer with eight years of unfiled returns · Where: Edmonton, Alberta · Engagement: 10 weeks, fixed fee
Cash freed$155,000
Compliance failuresNone
ReportingMonthly
The situation — A taxpayer with eight years of unfiled returns, Edmonton, Alberta
A taxpayer with eight years of unfiled returns in Edmonton, Alberta was opening in a second province. That meant different filing obligations and a different payroll regime. A net-worth assessment built on unexplained deposits that were actually loan proceeds already sat in the file.
What we did for A taxpayer with eight years of unfiled returns, Edmonton, Alberta
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. We then put monthly reporting in place. That let the owner see the cash effect of growth while there was still time to act on it.
The result — A taxpayer with eight years of unfiled returns, Edmonton, Alberta
Growth was absorbed without a compliance failure. $155,000 of cash was released, and the monthly reporting now flags a problem while it is still small.
Client: A taxpayer with frozen bank accounts · Where: Lethbridge, Alberta · Engagement: 3 weeks, fixed fee
Overpayment refunded$87,000
Late remittances sinceZero
ScheduleAutomated
The situation — A taxpayer with frozen bank accounts, Lethbridge, Alberta
Remittances at a taxpayer with frozen bank accounts in Lethbridge, Alberta were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat a waiver signed at the counter that kept an otherwise closed year open with no end date.
What we did for A taxpayer with frozen bank accounts, Lethbridge, Alberta
We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. Then we moved the remittance dates into a scheduled process rather than a monthly decision.
The result — A taxpayer with frozen bank accounts, Lethbridge, Alberta
Penalties stopped from the following remittance onwards, and $87,000 of overpaid instalments was refunded.
Client: A shareholder assessed on a taxable benefit · Where: Windsor, Ontario · Engagement: 3 weeks, fixed fee
Penalty cancelled$82,000
Relief applicationGranted
ReturnAccepted as filed
The situation — A shareholder assessed on a taxable benefit, Windsor, Ontario
A shareholder assessed on a taxable benefit in Windsor, Ontario had already missed one deadline and was about to miss a second. Behind it sat a proposal letter with a 30-day response window and no supporting records assembled. A penalty of $82,000 was accruing.
What we did for A shareholder assessed on a taxable benefit, Windsor, Ontario
We split the work into what had to happen before the deadline and what could follow it. Then we filed the Tax Court appeal inside the window and resolved the remaining adjustments before a hearing date was needed.
The result — A shareholder assessed on a taxable benefit, Windsor, Ontario
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $82,000 of the penalty already assessed on the earlier year.
Client: A corporation under a GST/HST review · Where: Brampton, Ontario · Engagement: 9 weeks, fixed fee
Annual saving$45,000
ReorganisationTax-neutral
StructureMatches operations
The situation — A corporation under a GST/HST review, Brampton, Ontario
The structure at a corporation under a GST/HST review in Brampton, Ontario needed fixing. The file was carrying a director liability assessment for a corporation that had already stopped operating. Every option for fixing it ran through a reorganisation that had to be done without triggering tax.
What we did for A corporation under a GST/HST review, Brampton, Ontario
We worked with the client's lawyer. Together, we filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely. We also prepared the elections, resolutions and valuations the structure needed to stand up.
The result — A corporation under a GST/HST review, Brampton, Ontario
The structure now matches the business. Annual saving of $45,000, and the reorganisation itself was tax-neutral.
Case Study 6 · Sale and succession
Intergenerational Transfer Completed With $815,000 Deferred — Family Business Under Review, Surrey
Client: A family business under a related-party review · Where: Surrey, British Columbia · Engagement: 8 weeks, fixed fee
Tax deferred$815,000
TransferCompleted
RecordsReview-ready
The situation — A family business under a related-party review, Surrey, British Columbia
A generational transfer at a family business under a related-party review in Surrey, British Columbia had been discussed for years without a plan. No valuation on file to support the price the parties had agreed meant the transfer as contemplated would have been fully taxable.
What we did for A family business under a related-party review, Surrey, British Columbia
We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn. We sequenced the steps so each one was complete and documented before the next depended on it.
The result — A family business under a related-party review, Surrey, British Columbia
$815,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
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.
