Client Profile
Two individual taxpayers who received CRA repayment demands related to government benefit programs during the COVID-19 period.
The Challenge
CRA had reassessed both clients on the basis that they did not qualify for benefits received during the relevant period, taking the position that qualifying income had been earned. The clients had limited documentary records and faced substantial repayment demands from CRA.
Our Approach
We compiled all available financial records including trust ledger evidence, commission records, and third-party documentation to establish that the clients had no qualifying income during the benefit period. We prepared detailed third-review submissions to CRA covering dividend characterisation, shareholder loan treatment, and supporting ledger evidence. When the CRA review remained unresolved, we filed Federal Court proceedings on behalf of both clients.
Result
The matters resolved by Minutes of Settlement, providing both clients with a negotiated resolution without the full cost and uncertainty of a contested Federal Court hearing.
Details have been anonymised to preserve client confidentiality. Past results do not guarantee future outcomes.