Corporation Canada Dissolution – Company Revival & TFSA Defense
Case Overview
A complex case combining Corporation Canada involuntary dissolution, CRA deemed income taxation, frozen bank accounts, and a civil tax dispute over TFSA contributions — all stemming from director negligence. Both corporate law and ITA/civil law were involved.
Challenge
Corporation Canada involuntary dissolution due to director negligence. Both Corporation Canada and CRA were involved regarding deemed income for the director/shareholder, and the bank account was frozen. The dissolution issue further extended to the director's TFSA, where CRA questioned the resident status of the director over an eight-year period (2016–2023) and denied all TFSA contribution amounts along with penalties and interest.
Result
Company revived to normal status. All CRA deemed tax income, penalties, and interest waived — total reduction of six-digit amounts. All denied TFSA contribution amounts, penalties, and interest waived — total amount over $100,000.
The Challenge
Company faced involuntary dissolution. CRA and Corporation Canada involved, with deemed income, frozen accounts, and TFSA disputes spanning 8+ years.
Our Approach
- Amended articles for Corporation Canada to revive company
- Negotiated with multiple CRA divisions per ITA
- Defended TFSA civil tax issue
The Resolution
CRA waived all deemed tax income, penalties, and interest (six-figure amount). TFSA disputes resolved – over $100,000 in denied contributions waived.