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Subsection 152(7)  ·  Indirect Verification  ·  Free Calculator

CRA Net Worth Assessment Calculator

The CRA has decided your assets grew by more than your reported income explains. Work out the imputed discrepancy, the tax, HST, penalty and interest built on it, and exactly how much every dollar you can document is worth.

Full assessment modelled
Cost per dollar shown
Both penalties included
The onus is on you

Step 1 — The Net Worth Build

Assets less liabilities at the start of the audit period


Assets less liabilities at the end


The discrepancy is spread across these


Total over the whole period. The CRA often estimates this high.


Gifts, inheritances, loans, insurance, sale of personal assets


Everything already on your returns, all years combined

Step 2 — How the CRA Is Framing It

Corporation and shareholder

Corporation and shareholder
Corporation only
Personally only

Owner-managed files are usually assessed on both sides

Yes

Yes
No

The same discrepancy is assessed again for HST

Yes

Yes
No

50% of income tax and 25% of HST


Sets the bracket the shareholder benefit stacks on

Total Exposure


total assessment

Imputed Discrepancy

Per Year

Total Assessment

Cost Per Dollar

How the CRA Builds the Number

StepBasisAmount

What Gets Assessed on It

AssessmentBasisAmount

What Every Documented Dollar Is Worth

If You SubstantiateDiscrepancy Falls ToAssessment Falls By

Where the Documents Usually Are

SourceWhat Proves It

Assessment Against the Discrepancy Itself

The imputed discrepancy
What is assessed on it

Points That Decide This

    What to Do Next

    Disclaimer: Subsection 152(7) permits the Minister to assess in the manner considered appropriate where a return has not been filed or is unsatisfactory, and the net worth method is one such approach. An assessment is presumed valid and the onus sits with the taxpayer to displace the Minister’s assumptions. Corporate tax is calculated at the Ontario combined small business rate of 11.2%, reflecting Ontario’s reduction to 2.2% effective 1 July 2026, and 26.5% above the $500,000 limit. HST is treated as included in the unreported amount at 13/113. The gross negligence penalty under subsection 163(2) is 50% of the understated income tax, and under section 285 of the Excise Tax Act it is 25% of the HST, and both require the CRA to establish the necessary standard of conduct. Interest is estimated at 8% compounded over a midpoint of the exposure period and the actual figure depends on the prescribed rates and reassessment dates. Where the shareholder is assessed on the same funds the corporation is assessed on, the amount is taxed twice, which is the position the CRA commonly takes on an owner-managed file. This page is general information and not tax advice, and no calculator substitutes for representation on a live audit.

    You Have to Disprove It, Not Them Prove It

    This is the single most important thing to understand, and it surprises everyone. A net worth assessment is presumed valid. The CRA does not have to prove you earned the money. You have to displace the assumptions they made.

    That reverses the instinct most people bring to it. Arguing that the method is crude, or that the CRA cannot possibly know what you earned, changes nothing. Producing a bank record showing where $80,000 came from changes everything.

    Every dollar you document comes straight off the top. On a typical owner-managed file the assessment runs to roughly $1.05 for every $1 of unexplained discrepancy, so substantiating $200,000 of a gift or loan removes about $233,000 of assessment. Nothing else you do on the file has that leverage.

    How the Number Is Built

    StepEffect
    Closing net worth less opening net worthThe increase in your wealth
    Plus personal and family living expensesMoney you must have earned to spend
    Less non-taxable receiptsThe only line that works in your favour
    Equals income for the periodWhat the CRA says you must have made
    Less income reportedWhat you actually declared
    Equals the discrepancyAssessed as unreported income

    It Gets Taxed Twice on an Owner-Managed File

    Where the CRA concludes that unreported corporate sales were taken personally, it typically assesses the corporation on the revenue and the shareholder on the appropriation. The same money, taxed on both sides.

    On a $730,000 DiscrepancyAmount
    HST at 13/113 of the amount$83,982
    Corporate tax on the revenue$72,354
    Personal tax on the shareholder benefit$261,761
    Gross negligence penalties$188,053
    Interest$157,424
    Total$763,574

    That is more than the discrepancy itself. A dollar the CRA says you did not report costs about $1.05 once both sides, both penalties and the interest are added. It is one of the few assessments in the system that can exceed the amount in dispute.

    The Four Places the Number Is Usually Wrong

    1. Opening net worth understated. If you already held cash, investments or property at the start and the CRA did not count it, the growth is overstated by exactly that amount. This is the most productive line of attack and the most commonly overlooked.
    2. Living expenses overstated. The CRA frequently applies statistical averages rather than what your household actually spent. If you live modestly, prove it with the bank records rather than accepting the estimate.
    3. Non-taxable receipts ignored. Gifts, inheritances, loans from family, insurance proceeds, sale of personal property, lottery winnings, contributions from a spouse or a cohabitant. Each is a dollar-for-dollar reduction.
    4. Double counting. An asset counted at closing that was also treated as an expenditure, or a loan counted as an asset without the matching liability.

    The Documents That Actually Work

    Source of FundsWhat Proves It
    A gift from familyThe transfer record and a statement from the giver, ideally with their own bank record showing the outflow
    An inheritanceThe will, the estate accounts and the distribution record
    A loanThe agreement, the advance, and evidence of repayments
    Sale of personal propertyThe bill of sale and the deposit matching it
    Funds brought from abroadWire records and the foreign source account
    A spouse’s contributionTheir own income records and the transfers

    A statement without a bank trail is weak. A bank trail without an explanation is weak. The two together are what moves an auditor.

    The Gross Negligence Penalty Is Fightable

    The penalty is 50% of the understated income tax and 25% of the HST, and the burden of proving it sits with the CRA rather than with you. That is the one part of the file where the onus is reversed in your favour.

    Establishing that the underreporting arose from poor records, bad advice or genuine confusion rather than knowing conduct or indifference frequently removes the penalty even where the underlying assessment largely stands. On the figures above that alone is $188,000.

    The Years Do Not Close

    The normal three-year reassessment period does not apply where there has been a misrepresentation attributable to neglect, carelessness or wilful default, which is precisely what a net worth assessment alleges. Older years stay open.

    What to Do When the Letter Arrives

    1. Do not answer questions from memory. Early informal explanations that later turn out to be wrong are used against you for the rest of the file.
    2. Get representation before the proposal letter becomes an assessment. Fixing it at audit is far cheaper than at objection, and far cheaper again than at the Tax Court.
    3. Rebuild the opening net worth first, because it is the highest-value correction available.
    4. Gather the third-party records, meaning bank statements, the giver’s records, estate documents and loan agreements.
    5. Address the penalty separately from the quantum, because it turns on conduct rather than arithmetic.
    6. Watch the objection deadline, which is ninety days from the notice of assessment and is not forgiving.

    Do not ignore the assessment because the number looks impossible. Collection proceeds on the assessed amount whether or not it is right, and a net worth assessment that goes unchallenged past the objection deadline becomes final regardless of how wrong it was.

    What This Calculator Does Not Cover

    • The specific assumptions in your proposal letter, which is what representation actually addresses
    • Provincial variation outside Ontario
    • Criminal investigation, which is a different process with different rights
    • Director liability for the HST portion
    • Payment arrangements and collections holds during an objection
    • Taxpayer relief on the interest, which is a separate application

    Every hour spent finding a document is worth more than an hour spent arguing about method. Our net worth assessment service covers the rebuild, the submissions and the objection.

    Frequently Asked Questions

    Common questions from businesses under a net worth audit.

    How does a CRA net worth audit work?
    The CRA compares your net worth at the start and end of a period, adds your personal and family living expenses, subtracts documented non-taxable receipts, and treats the result as your income. Anything above what you reported is assessed as unreported income. It is an indirect method used where the books are unsatisfactory, and subsection 152(7) permits it.

    Does the CRA have to prove I earned the money?
    No, and this catches almost everyone. The assessment is presumed valid and the onus is on you to displace the assumptions behind it. Arguing that the method is crude achieves nothing. Producing a bank record showing where a deposit came from achieves everything, because each documented dollar reduces the discrepancy directly.

    How much does a net worth assessment actually cost?
    Roughly $1.05 for every $1 of unexplained discrepancy on a typical owner-managed file. On a $730,000 discrepancy that is about $763,000, made up of HST, corporate tax, personal tax on the shareholder benefit, gross negligence penalties and interest. It is one of the few assessments that can exceed the amount in dispute, because the same money is taxed on both the corporate and the personal side.

    How do I fight a net worth assessment?
    Attack the inputs rather than the method. Opening net worth is usually understated, because assets you already held were not counted. Living expenses are often based on statistical averages rather than your actual spending. Non-taxable receipts such as gifts, inheritances and loans reduce the discrepancy dollar for dollar. And double counting is common where an asset appears at closing and again as an expenditure.

    What documents will the CRA accept?
    Third-party records, not assertions. For a gift, the transfer record plus the giver’s own bank statement showing the outflow. For an inheritance, the will and the estate accounts. For a loan, the agreement, the advance and evidence of repayments. A statement without a bank trail is weak, and a bank trail without an explanation is weak. The two together are what moves an auditor.

    Can the gross negligence penalty be removed?
    Often, and it is the one part of the file where the burden sits with the CRA rather than with you. It is 50% of the understated income tax and 25% of the HST. Showing that the underreporting arose from poor records, bad advice or genuine confusion rather than knowing conduct frequently removes it even where the underlying assessment largely stands. On a $730,000 discrepancy that is roughly $188,000.

    Can they go back more than three years?
    Yes. The normal three-year limit does not apply where there has been a misrepresentation attributable to neglect, carelessness or wilful default, which is exactly what a net worth assessment alleges. Older years stay open, and audits of this kind routinely cover four to six years.

    What if I ignore it?
    It becomes final. Collection proceeds on the assessed amount whether or not it is right, including bank garnishment and liens, and an assessment left past the ninety-day objection deadline stands regardless of how wrong it was. The number looking impossible is not a reason to leave it. It is the reason to deal with it immediately.

    An Hour Finding a Document Beats an Hour Arguing About Method

    Send us the proposal letter and whatever records exist. We rebuild the opening net worth, document the non-taxable receipts, challenge the living expense estimate and address the penalty separately from the quantum.

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