Talk to the people who would run your file: fixed fees agreed in writing before work starts, and a named adviser who answers for it.
Everything about how this practice runs comes from one decision: the fee is agreed in writing before the work starts, and it does not move.
Further down: how we work, what clients ask before engaging us, two completed files with figures, the way the work runs, and where the fee is published.
Everything about how this practice runs comes from one decision: the fee is agreed in writing before the work starts, and it does not move. That single commitment sets the scope conversation, the review standard and the way we say no to work we should not take.
This is the point most filings get wrong. The difference between the two outcomes is a provision most people in this position have never heard of — and once it is identified, the rest of the file is straightforward.
I have been quoted by the hour before and had no idea what the final number would be.
I want to know who is actually reviewing my return, not which brand is on the letterhead.
My last accountant did not understand the second country at all.
None of those is unusual and none of them is a reason to be embarrassed. They are the normal consequence of a system that asks an individual to reconcile two sets of rules that were never designed to fit together. See also in the press.
The same point, with figures rather than adjectives.
Take C$145,000 of income taxed in both countries. Assume the other country charged 19% on it and the home country would charge 41% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$145,000 |
| Tax paid abroad (assumed 19%) | C$27,550 |
| Home tax on the same income (assumed 41%) | C$59,450 |
| Credit available (lesser of the two) | C$27,550 |
| Home tax still payable | C$31,900 |
The credit absorbs C$27,550 and leaves C$31,900 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.
An illustration, not a client file. The sums are chosen for legibility and the thresholds are stated for the example alone — nothing reaches a filing until it has been confirmed at source for your own year.
Numbers make this concrete, so here is the same rule applied to a set of figures.
Take C$96,000 of income taxed in both countries. Assume the other country charged 19% on it and the home country would charge 26% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$96,000 |
| Tax paid abroad (assumed 19%) | C$18,240 |
| Home tax on the same income (assumed 26%) | C$24,960 |
| Credit available (lesser of the two) | C$18,240 |
| Home tax still payable | C$6,720 |
The credit absorbs C$18,240 and leaves C$6,720 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. We run this on your actual numbers before advising anything, because the conclusion can invert with a modest change in inputs.
The figures here are an illustration, not an engagement: amounts are picked so the mechanism is easy to follow, and every rate or threshold is an assumption of the example. Before anything is filed for you, each one is confirmed with the issuing authority for your own tax year.
The first call establishes whether there is work to do. Everything after that is quoted.
Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. General guidance only. Your own facts decide the answer, so bring them to a call before relying on this.
The search that brings most people to this page is international tax accountant. It is answered here for careers: what creates the obligation, which filings discharge it, and the fee agreed before the work starts.
The preparer joined partway through a multi-year catch-up, which is the hardest point to join at. Rather than hand over the documents, the adviser who scoped the file wrote out the decisions already taken: the residence position, why the years were being filed in that order, and what had been ruled out. The new preparer worked the remaining years against that note. What it produced was a file whose reasoning an outsider could follow. Handovers that pass only the paperwork tend to produce a fresh set of decisions quietly contradicting the first.
The reviewer read a return and did not accept the treatment of one item. Neither view was obviously wrong; the rule could be read both ways on those facts. The work consisted of setting both readings down in writing with the facts each depended on, and testing which of those facts the documents actually supported. The reading that would have produced the better answer turned out to rest on something nobody had evidenced. The engagement produced a filed return and a written note of why the alternative was rejected, which is what an adviser needs if the position is ever questioned.
An experienced preparer joined having filed in one jurisdiction only. The technical gap was not the difficulty. The difficulty was that nothing in a domestic return signals that another country's rules might govern it. The work consisted of running live files alongside a reviewer whose first question was always which system had the prior claim, until the preparer asked it unprompted. What it produced was not a qualification but a habit. The error being trained out is confident application of a well-known rule to facts it was never written for.
A file was quoted on a description that turned out to understate it, and because the fee had been agreed in writing it did not move. The work was completed at the agreed price. What the engagement produced, beyond the filing, was a change to the scoping conversation: the questions that would have surfaced the missing part are now asked before a fee is given, on every file of that kind. A fixed fee makes a bad scope visible immediately. That is most of its value internally, quite apart from what it does for the client.
The records sat in one country and the filing obligation in another, so preparation and review happened in different offices. A single named adviser stayed answerable for the file throughout and was the only person who spoke to the client about it. Everything crossing between offices went in writing. What the arrangement produced was a single account of the file that matched what the client had been told. Where that role is not held by a named person, the offices tend to develop slightly different versions of the same engagement.
A returning client's position had been settled several years earlier on facts that were not obvious from the return itself. The same reviewer picked the file up each year, which meant the question of why that position was taken did not have to be reopened annually. The work consisted of reading the earlier note, confirming the facts had not changed, and filing. What continuity produces is cheap consistency. Where a file changes hands every year, a settled position gets quietly restated, and each restatement is an opportunity to contradict the one before.
A dependent agent habitually concluding contracts can create a permanent establishment where there is no premises at all. The review tests what the person actually does against what the treaty describes.
Read how this one runsThe two countries classify the vehicle differently, so relief that ought to apply frequently does not and the same profit can be taxed in both hands. The engagement examines whether the structure can be changed and what the change itself costs.
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.
Less arithmetic than people expect and far more reading. A file starts with a question of fact — where someone lived, where the work was performed, which entity actually bore a cost — and most of the day goes on establishing that from documents rather than on preparing a return. Then comes the question of which country's rules take precedence, and whether a treaty changes the default. The return itself is usually the last and shortest part. People who enjoy this work tend to be the ones who like the reading. People who came for the software do not stay long.
It helps, but the harder requirement is knowing where your own knowledge stops. The characteristic error on cross-border work is applying a rule you know well to a fact pattern it was never written for, confidently, because nothing on the form tells you it is the wrong rule. Someone who has filed in a single country and says so plainly is easier to work with than someone who assumes the other system must work roughly the same way. A second system can be learned on live files with a reviewer. The habit of checking which rule governs before preparing anything cannot be taught as quickly.
A return is read by someone other than the person who prepared it, and the review is not a recalculation. The reviewer is checking the decisions: which residence position was taken, why one country was treated as taxing first, which years were included and why. Where those decisions are not obvious from the file, they are written down. That note is what makes a position defensible later, sometimes years later, when the person who made it has moved on. Preparers coming from volume practices usually find this the biggest change. The work is not finished when the figures agree.
Accurate scoping, mainly. When the fee is agreed in writing before the work starts and does not move, an optimistic view of what a file contains is not absorbed by a timesheet — it is absorbed by whoever priced it. So people here are expected to say early and plainly when a file is not what it was described as, rather than working quietly through the difference. It also means nobody is rewarded for taking longer. The pressure runs the other way, which makes the review step more important rather than less.
There are offices in India, the United States, Canada and the United Arab Emirates, and most files touch more than one of them. That shapes the work in a way worth understanding before applying: a file is often prepared where the records sit and reviewed where the filing obligation is, so a piece of work regularly passes between people in different offices. Being able to write down what you have decided, and why, in a form someone who has not spoken to the client can follow, matters more here than it would in a single-office practice.
Call +1 (416) 619-0068 and say which office you are enquiring about. What is worth setting out, more than a list of employers, is the work itself: which countries you have filed in, what kinds of file you have taken from first conversation to signature, and where you have had to defend a position rather than only prepare one. If you have never worked across a border, say so and describe what you have done in depth instead. Depth in a single system is a better starting point than a shallow acquaintance with several.
It is legal. Two countries can each have a valid claim on the same income — one because the income arose there, the other because you live there — and nothing prohibits both from exercising it. What exists instead is relief: tax treaties allocate the claim, and domestic law gives a credit for foreign tax paid. The relief is not automatic, though. It is claimed on a return, and unclaimed relief is simply lost. See how double taxation is relieved.
Both countries have routes back, and using one before they contact you is what preserves the relief. On the US side there are procedures aimed at taxpayers whose failure was not wilful, including one designed for people living outside the country, and separate procedures for late account reports and information returns alone. Canada has its voluntary disclosures programme and taxpayer relief for penalties and interest. Filing quietly and hoping is the one approach with no protection attached to it. See catch-up filing.
Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.
