Tax Lien Review Case Studies

6 Tax Lien Review 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 tax lien review work, not a general example.

Case Study 1 · Missed incentive claimed

$89,000 In Credits Claimed That Prior Filings Had Missed — Corporation Under a GST/HST, Halifax

Client: A corporation under a GST/HST review  ·  Where: Halifax, Nova Scotia  ·  Engagement: 8 weeks, fixed fee

Credits claimed$89,000
Years adjusted7
Review outcomeNo adjustment

The situation

A corporation under a GST/HST review in Halifax, Nova Scotia had been filing for 7 years without ever claiming the incentives its activity qualified for. Behind that sat a director liability assessment for a corporation that had already stopped operating.

What we did

We tested each activity against the eligibility criteria rather than the description on the invoice, then filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely.

The result

$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 — Taxpayer with Frozen Bank, Edmonton

Client: A taxpayer with frozen bank accounts  ·  Where: Edmonton, Alberta  ·  Engagement: 10 weeks, fixed fee

Cash freed$155,000
Compliance failuresNone
ReportingMonthly

The situation

A taxpayer with frozen bank accounts in Edmonton, Alberta was opening in a second province — different filing obligations, a different payroll regime, and a director liability assessment for a corporation that had already stopped operating already in the file.

What we did

We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn and put monthly reporting in place so the owner could see the cash effect of growth while there was still time to act on it.

The result

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.

Case Study 3 · Cash and remittance control

Remittance Schedule Corrected, $87,000 Refunded — Contractor Facing a Proposed, Lethbridge

Client: A contractor facing a proposed reassessment  ·  Where: Lethbridge, Alberta  ·  Engagement: 3 weeks, fixed fee

Overpayment refunded$87,000
Late remittances sinceZero
ScheduleAutomated

The situation

Remittances at a contractor facing a proposed reassessment in Lethbridge, Alberta were consistently late by a few days, which was enough to trigger penalties every quarter. Behind it sat a net-worth assessment built on unexplained deposits that were actually loan proceeds.

What we did

We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action, then moved the remittance dates into a scheduled process rather than a monthly decision.

The result

Penalties stopped from the following remittance onwards, and $87,000 of overpaid instalments was refunded.

Case Study 4 · Deadline rescue

$82,000 Late-Filing Penalty Cancelled On Relief Application — Professional Under a Lifestyle, Windsor

Client: A professional under a lifestyle audit  ·  Where: Windsor, Ontario  ·  Engagement: 3 weeks, fixed fee

Penalty cancelled$82,000
Relief applicationGranted
ReturnAccepted as filed

The situation

A professional under a lifestyle audit in Windsor, Ontario had already missed one deadline and was about to miss a second. Behind it sat six years of unfiled corporate and personal returns and an active collections file, and a penalty of $82,000 was accruing.

What we did

We split the work into what had to happen before the deadline and what could follow it, then traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly.

The result

The outstanding return was accepted as filed, and the taxpayer relief application cancelled $82,000 of the penalty already assessed on the earlier year.

Case Study 5 · Structure rebuilt

Holding Structure Added, $45,000 Saved Annually — Importer Under a Customs, Brampton

Client: An importer under a customs and GST audit  ·  Where: Brampton, Ontario  ·  Engagement: 9 weeks, fixed fee

Annual saving$45,000
ReorganisationTax-neutral
StructureMatches operations

The situation

An importer under a customs and GST audit in Brampton, Ontario was carrying a proposal letter with a 30-day response window and no supporting records assembled, and every option for fixing it ran through a reorganisation that had to be done without triggering tax.

What we did

Working with the client's lawyer, we filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely and prepared the elections, resolutions and valuations the structure needed to stand up.

The result

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 — Business Owner with a, Surrey

Client: A business owner with a director liability assessment  ·  Where: Surrey, British Columbia  ·  Engagement: 8 weeks, fixed fee

Tax deferred$815,000
TransferCompleted
RecordsReview-ready

The situation

A generational transfer at a business owner with a director liability assessment 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

We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn, sequencing the steps so each one was complete and documented before the next depended on it.

The result

$815,000 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.

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