CRA Appeals Assistance Case Studies

6 CRA Appeals 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 cra appeals assistance work, not a general example.

Case Study 1 · Backlog brought current

Collections Halted And $138,000 Cut From A 3-Year Backlog — Business Owner with a, Barrie

Client: A business owner with a director liability assessment  ·  Where: Barrie, Ontario  ·  Engagement: 4 weeks, fixed fee

Balance reduced by$138,000
Backlog cleared3 years
CollectionsHalted

The situation

By the time a business owner with a director liability assessment in Barrie, Ontario called, 3 years were outstanding and the CRA had assessed on estimates. Underneath it sat a proposal letter with a 30-day response window and no supporting records assembled.

What we did

We reconstructed the records year by year and traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly. Each filing replaced an arbitrary assessment with a real one.

The result

The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $138,000, and a relief application addressed part of the accumulated interest.

Case Study 2 · Structure rebuilt

Corporate Structure Rebuilt For $23,000 Of Annual Savings — Taxpayer with Frozen Bank, Victoria

Client: A taxpayer with frozen bank accounts  ·  Where: Victoria, British Columbia  ·  Engagement: 3 weeks, fixed fee

Saving per year$23,000
DocumentationComplete
Transfer basisRollover

The situation

The structure at a taxpayer with frozen bank accounts in Victoria, British Columbia had been set up years earlier for a business that no longer existed, and a director liability assessment for a corporation that had already stopped operating had become expensive.

What we did

We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.

The result

$23,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.

Case Study 3 · Objection and relief

Desk-Review Assessment Of $83,000 Vacated — Restaurant Under a Net-Worth, Regina

Client: A restaurant under a net-worth audit  ·  Where: Regina, Saskatchewan  ·  Engagement: 9 weeks, fixed fee

Assessment vacated$83,000
Supporting recordsNow on file
AccountCleared

The situation

A restaurant under a net-worth audit in Regina, Saskatchewan was carrying $83,000 of penalties and interest arising from six years of unfiled corporate and personal returns and an active collections file, much of it accumulated during a period the CRA itself had delayed.

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 framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.

The result

The assessment was vacated. $83,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.

Case Study 4 · Deadline rescue

$100,000 Late-Filing Penalty Cancelled On Relief Application — Corporation Under a GST/HST, London

Client: A corporation under a GST/HST review  ·  Where: London, Ontario  ·  Engagement: 3 weeks, fixed fee

Penalty cancelled$100,000
Relief applicationGranted
ReturnAccepted as filed

The situation

A corporation under a GST/HST review in London, Ontario had already missed one deadline and was about to miss a second. Behind it sat an objection deadline that had passed with no extension applied for, and a penalty of $100,000 was accruing.

What we did

We split the work into what had to happen before the deadline and what could follow it, then filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely.

The result

The outstanding return was accepted as filed, and the taxpayer relief application cancelled $100,000 of the penalty already assessed on the earlier year.

Case Study 5 · Records and systems rebuilt

Month-End Close Cut From 9 Weeks To 6 Days — Company Facing a Payroll, Surrey

Client: A company facing a payroll trust examination  ·  Where: Surrey, British Columbia  ·  Engagement: 3 weeks, fixed fee

Close time before9 weeks
Close time after6 days
Year-endReview, not rebuild

The situation

The accounting file at a company facing a payroll trust examination in Surrey, British Columbia was built on a net-worth assessment built on unexplained deposits that were actually loan proceeds. The year-end had taken 9 weeks each of the last three years.

What we did

We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly 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 6 days instead of 9 weeks, and the year-end is a review rather than a reconstruction.

Case Study 6 · Cash and remittance control

Instalments Rebased, $117,000 Of Cash Returned To The Business — Importer Under a Customs, Ottawa

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

Cash returned$117,000
Instalment basisCurrent year
ReviewedQuarterly

The situation

An importer under a customs and GST audit in Ottawa, Ontario was paying instalments calculated on a prior year that no longer reflected the business. A proposal letter with a 30-day response window and no supporting records assembled was tying up $117,000 of cash.

What we did

We rebased the instalments on the current-year estimate rather than the prior-year default, and brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action.

The result

$117,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.

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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