International & Cross-Border Tax Advisors for Individuals & Multi National Corporations

Software revenue crosses borders by default — sourcing rules, withholding on licence-like payments and IP location decide the effective rate.

Software revenue is rarely taxed where the team sits. Licence, subscription and service income are characterised differently by each side, and the answer decides withholding at source, treaty relief and whether a foreign customer creates a taxable presence at all — questions that are cheap to settle before the contract and expensive afterwards.

• Cross-border revenue sourcing & withholding
• IP structuring with real substance
• Equity for cross-border teams
• U.S. expansion: entity & PE setup

Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.

A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.

• Reg 105 / 102 waivers
• Permanent establishment risk
• Partner mobility planning
• Cross-border withholding recovery

Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.

Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.

• Section 216 rental returns
• FIRPTA withholding recovery
• Section 116 clearance
• Treaty credit optimization

Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.

Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.

• Transfer pricing documentation (s.247)
• Customs value vs transfer price
• Foreign affiliate reporting (T1134)
• Country-by-country reporting

Performance income is taxed where earned — Regulation 105 in Canada, withholding agreements in the U.S. — with special treaty articles overriding the usual rules.

Performance income is taxed where the performance happens, and the deduction is usually taken at source on the gross fee before expenses. Recovering the difference is a filing exercise in the other country, and it only works if the tour, the residency and the withholding certificates were documented while the work was being done.

• Reg 105 & U.S. CWA agreements
• Multi-state & country calendars
• Touring income allocation
• Royalty & image-rights withholding

Working from anywhere doesn't mean taxed nowhere: residency defaults, employer payroll exposure and treaty relief decide where income actually lands.

Working from another country does not by itself end tax residence in the one you left, and it can start one where you are sitting. Day counts, ties, the employer's own exposure and the treaty tie-breaker all point at the same question, and the year you move is the year it has to be answered on paper.

• Residency analysis before moving
• Employer payroll exposure
• Totalization & social security
• Foreign tax credits

Holding structures live or die on treaty access, beneficial ownership and substance — the MLI's principal-purpose test now sits over every arrangement.

A holding structure is only as good as its reporting. Foreign affiliates, accrued passive income and distributions each carry their own return, and the penalties on those attach to the form rather than to any tax being owed — so a structure that saves tax can still cost money if the information returns are late.

• Treaty access & PPT reviews
• FAPI & surplus computations
• Withholding-efficient routing
• Governance & substance