Finished cross-border files, published with what came in, what was filed and what it cost — so you can judge us before you call.
The claims on this site are deliberately few: fixed fees agreed in writing before work starts, 15+ years of cross-border experience, 18,000+ clients served across 4 global offices, a 5.0/5 Google rating, and a helpline that answers 24 hours a day.
On this page: how the practice runs, the questions clients ask first, two finished files with their numbers, how an engagement runs, and the fee it starts from.
The claims on this site are deliberately few: fixed fees agreed in writing before work starts, 15+ years of cross-border experience, 18,000+ clients served across 4 global offices, a 5.0/5 Google rating, and a helpline that answers 24 hours a day. Anything that cannot be evidenced does not go on a page.
The question below is the one that actually determines the outcome. Two people with identical incomes and identical passports can owe completely different amounts because one of them falls inside a provision the other does not. That is the whole reason this page exists as its own page rather than as a paragraph on a general one.
Every firm says the same things — I want to see the actual outcome.
I want to know what a file like mine looked like when it was finished.
I need to see that someone has handled my exact combination of countries.
We hear versions of all three most weeks. The confusion is structural rather than personal: nothing in either system is designed to explain the other. See also why fixed fees, not hourly rates.
Put numbers against it and the shape of the answer is obvious.
Take C$157,000 of income taxed in both countries. Assume the other country charged 20% on it and the home country would charge 43% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$157,000 |
| Tax paid abroad (assumed 20%) | C$31,400 |
| Home tax on the same income (assumed 43%) | C$67,510 |
| Credit available (lesser of the two) | C$31,400 |
| Home tax still payable | C$36,110 |
The credit absorbs C$31,400 and leaves C$36,110 payable at home, because the home rate on this income is the higher of the two. The balance is real cash and it is due on the home timetable, which is why instalments get raised in the first meeting. Change any one of those inputs and the answer moves, which is why we run it on your own figures rather than on an illustration.
Treat these numbers as a worked example rather than advice — they exist to make the mechanics visible, and the rates and thresholds are assumed for the illustration. For a real filing, we verify each figure with the authority that publishes it, for your year.
It is easier to see with numbers attached.
Take C$96,000 of income taxed in both countries. Assume the other country charged 32% on it and the home country would charge 29% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$96,000 |
| Tax paid abroad (assumed 32%) | C$30,720 |
| Home tax on the same income (assumed 29%) | C$27,840 |
| Credit available (lesser of the two) | C$27,840 |
| Home tax still payable | C$0 |
The credit fully absorbs the home liability on this income, so nothing further is payable at home — but the return still has to be filed and the credit still has to be claimed, by category and by country. Change any one of those inputs and the answer moves, which is why we run it on your own figures rather than on an illustration.
Treat these numbers as a worked example rather than advice — they exist to make the mechanics visible, and the rates and thresholds are assumed for the illustration. For a real filing, we verify each figure with the authority that publishes it, for your year.
We will tell you if you do not need us. That happens more often than you would expect.
Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
The subject here is cross-border situations we are asked about, which is what people mean when they search for international tax accountant. This page covers who it applies to, the filings it produces, and the fixed fee agreed before work begins.
The executor came to us after probate had started, holding a schedule of assets in two countries and no clear idea which return reported what. The work was a sequencing exercise: establish the deceased's residence position, separate the assets taxed on death from those taxed on later distribution, and identify which country had first claim over each. The engagement produced a filing plan the executor could work to, a written note of the treaty position taken on the foreign-situated assets, and the terminal return with its supporting schedules, prepared to a fixed fee agreed in writing before the work began.
The enquiry came from the employer rather than the employee, after payroll had continued unchanged through a posting abroad. We established when the employee's residence actually changed, which country's payroll withholding applied from that date, and whether the posting created a filing obligation for the employer in the destination country. The work consisted of reconstructing the payroll year, correcting the withholding position going forward, and drafting the note the employer would rely on if the arrangement were examined. It produced corrected payroll reporting, a memorandum on the treaty article relied upon, and a written position the employee could file on.
She had left one country, kept a home there, and begun working from the other without severing much else. The question she arrived with was which return to file; the question that decided the file was which country she was resident in under the treaty tie-breaker, and from what date. The work was evidential rather than computational: a chronology of ties, the documents that supported each of them, and an assessment of where the balance sat. The engagement produced a dated residence memorandum with its supporting schedule, and a filing position she could give to either revenue authority on request.
The owner had emigrated and kept a flat that was let. Nobody had told the tenant or the managing agent that anything had changed, so rent continued to be handled as though the owner still lived there. We set out the non-resident position, explained why withholding on a property held by a non-resident is applied to rent received rather than to profit, and put the elective route to being taxed on net rental income in front of the client. The work produced a corrected withholding arrangement with the agent, the election filed, and the outstanding rental years brought up to date.
The account surfaced during ordinary document gathering for a return, not through any enquiry from a revenue authority. The first work was to establish the facts: when the account was opened, who controlled it, what income it produced, and which years were affected. Only then could the route for coming forward be assessed, since arriving at a disclosure with an incomplete set of years tends to make matters worse rather than better. The engagement produced a reconstructed income schedule for the affected years, a written chronology, and a disclosure submitted with its supporting documents attached rather than promised.
The group had been charging a related company for services for several years on an invoice that named no basis for the charge. The immediate question was not whether the charge was too high, but whether anything on file explained how it had been set. The work consisted of describing the services actually performed, testing the charge against what an unrelated provider would have been paid for them, and writing the intercompany agreement that should have existed from the start. It produced a signed agreement, a contemporaneous pricing memorandum, and a documentation file the group can hand over if asked.
Days in the United States accumulate across three years, and enough of them make you a US resident for tax regardless of immigration status. The file counts the days properly and files the statement that keeps the position closer connection rather than residence.
Read how this one runsPension and annuity payments to a non-resident carry a flat withholding that often exceeds what a return would produce. The alternative filing is elective, and whether it helps depends on the total income for the year rather than on the payment alone.
Read how this one runsAll case studies — every published engagement in one place.
Strategy and compliance for income, assets and families spread across borders.
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.
On the first call we establish the scope — countries, years, entities, filings — and quote a fixed fee for it in writing. If the scope changes we re-quote before continuing, and nothing is filed until you have approved it.
That is how most of these engagements run. They keep the domestic file, we take the cross-border piece, and the boundary is agreed in writing so nothing is done twice or missed.
That is what this page is for. Each write-up states what the client arrived with, what the work consisted of, and what was filed or documented at the end. Details that could identify a person are removed, and nothing is added to make a file look tidier than it was. Read the two or three that sit closest to your own facts, then ring the number on this page and say which one you recognised. It is a faster start than describing your situation from scratch, and it tells us early whether your file is one we should take.
Names, employers, cities and dates come out first. What stays is the mechanism: the provision that governed the outcome, the order the work ran in, and the document that closed it. A cross-border file is recognisable by its shape rather than by its amounts, so a reader in the same position can usually tell within a paragraph whether it matches theirs. Where a figure would identify someone, or where we cannot evidence it, it is left out entirely rather than rounded into something vague. Clients are told before anything from their file is described in public.
Because residence, treaty position and the source of each item of income are decided separately from the amount. One person may be resident in a country under its domestic rule and non-resident under the treaty tie-breaker; another may hold the same passport but have severed different ties on leaving. A payment that is employment income in one country can be pension or business income in the other, and the country with first taxing rights changes with it. That is why the first conversation is about facts and documents rather than totals, and why a quote cannot sensibly be given before the position is identified.
Yes, where the client agrees to it, because those are the ones with something to teach. A file that arrived after a deadline had passed, or where a document simply did not exist, ends differently from one that arrived early, and pretending otherwise would make every write-up on this page useless. What we do not publish is an outcome presented as a saving, because the comparison it implies — what some other adviser would have done — is not something anyone can evidence. The write-up says what was filed, what was documented, and what was still outstanding at the end.
Usually, but as a map of the questions rather than of the answer. The value is in the order of work: what had to be established before anything could be filed, which document the position depended on, and where the file could have gone wrong. Copy the conclusion and you will very likely apply a rule that does not govern your facts, since most cross-border outcomes turn on residence and timing rather than on the type of income. Read the write-up for the questions it asks, bring your own documents, and let the position be established on those.
The ones that are finished, that a client has agreed we may describe, and that answer a question we are asked repeatedly. Files still in progress are not written up, because the outcome can still change and a published half-file is a claim rather than a record. We also leave out anything whose facts are so narrow that no reader could apply them. Where the same situation appears again and again it is written once and kept current, and the adviser who ran it is named, so a reader can put the question to the person who did the work.
In this order. Fix your residence under each country's own rules, and if both claim you, apply the treaty tie-breaker. Identify where each type of income is sourced. Read the article that covers that income type, because it decides who taxes and at what maximum rate. Then claim the relief on the residence-country return, with proof of the foreign tax. Most of the tax people lose to double taxation is lost at the last step, not the first. See how double taxation is relieved.
The treaty has a procedure for exactly that. You apply to the competent authority in your residence country, which takes the case up with its counterpart, and the two negotiate a position that removes the double taxation. Some treaties add binding arbitration if they cannot agree. It is slow and it runs on documents, so the practical work is preserving the record and filing protective claims while the clock runs. See our treaty work.
Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.
