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. An ordinary preparer will get the general position right and miss the specific one, because the specific one is not on the form. It has to be known about, claimed, and supported.
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.
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 what we never charge for.
The arithmetic is more persuasive than the description, so:
Take C$155,000 of income taxed in both countries. Assume the other country charged 20% on it and the home country would charge 32% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$155,000 |
| Tax paid abroad (assumed 20%) | C$31,000 |
| Home tax on the same income (assumed 32%) | C$49,600 |
| Credit available (lesser of the two) | C$31,000 |
| Home tax still payable | C$18,600 |
The credit absorbs C$31,000 and leaves C$18,600 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. The shape of that result holds; the size of it depends entirely on your own numbers and dates.
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.
It is easier to see with numbers attached.
Take C$141,000 of income taxed in both countries. Assume the other country charged 32% on it and the home country would charge 27% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$141,000 |
| Tax paid abroad (assumed 32%) | C$45,120 |
| Home tax on the same income (assumed 27%) | C$38,070 |
| Credit available (lesser of the two) | C$38,070 |
| 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. That is an illustration of the mechanism, not a prediction about your file — the same computation on your figures is the first thing we do.
Example figures throughout, selected to make the rule visible, with rates and thresholds assumed for the demonstration. Your actual filing uses figures confirmed with the issuing authority for your tax year.
We will tell you if you do not need us. That happens more often than you would expect.
Reviewed for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. Published as general information. For a position on your own file, call the 24-hour helpline.
Most readers of this page are looking for international tax accountant. What follows sets out how it works for how a GST/HST audit gets narrowed: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.
The opening request covered several reporting periods and asked for everything behind them. Instead of sending the underlying records period by period, the work began with a reconciliation tying reported sales to the bank and to the ledger, with the differences named and explained. That went first, with the supporting documents indexed behind it. Most of the opening questions were answered by the reconciliation itself. What the engagement produced was an audit that stayed within the periods named in the letter, because nothing in the answer suggested a reason to look outside them.
Credits had been claimed from internal records where the supplier invoice had never been obtained, and they were denied on that basis. The entitlement was real; the evidence was not there. The work consisted of identifying every claim resting on an internal record, going back to each supplier for a document showing their registration and the tax charged, and resubmitting them as a schedule tied to the original claims. What it produced was the restoration of the claims that could be evidenced and a written acceptance of those that could not, which ended the argument rather than prolonging it.
Sales had been treated as zero-rated exports, and the auditor accepted that the customer was abroad but not that the goods had gone. That distinction is the whole of the test. The work consisted of assembling, for each shipment, the carrier documentation and the delivery evidence showing where the goods ended up, and matching it to the invoices. What the engagement produced was a documented export file for the sales that could be evidenced, and an agreed adjustment for the handful where the paperwork genuinely did not exist. The treatment was never the issue. Proof of movement was.
Services were billed to a foreign parent and treated accordingly, and the auditor's view was that the supply was made where the work was performed. That reading would have brought the whole class of invoices into charge. The work consisted of establishing, from the contracts and the correspondence, who the recipient of the service actually was and where that recipient was established. What it produced was a documented place-of-supply position, argued from the agreements rather than from the address on the invoice, and applied consistently across every period under review.
The proposal letter set out the auditor's reasoning for the first time, and some of the factual premises in it were wrong. Written representations went back identifying each premise, evidencing the correction and leaving the conclusions to follow. The remaining adjustments were accepted in the same letter, which made clear what was actually in dispute. What the engagement produced was an assessment issued on the corrected facts, so there was nothing left to object to afterwards. Answering at the proposal stage costs a fraction of arguing the same points against an assessment already raised.
The business sold a piece of equipment as an isolated transaction and treated it as outside its ordinary trading, so no tax was accounted for on it. The audit picked it up from the bank. The work consisted of establishing how the asset had been treated when it was acquired and whether the sale fell to be taxed on that basis, then quantifying the amount and disclosing it before the auditor completed the review. What it produced was a disclosed and corrected period, and a written procedure for asset disposals so the next one is caught by the books rather than by an auditor.
Residence is decided on ties, not on a form, and the review asks for evidence of every one of them. The file assembles the ties that were severed and the ones that remained, and answers the questionnaire against the treaty rather than around it.
Read how this one runsMost notices are proposals rather than assessments, and they carry a response window that is shorter than it looks. The engagement reads what is actually being proposed, gathers the support, and replies inside the window with the position rather than a request for time.
Read how this one runsAll case studies — every published engagement in one place.
Strategy and compliance for income, assets and families spread across borders.
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.
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.
The opening request is usually broad: the returns for the periods under review, the working papers behind them, sales and purchase listings, and bank records to tie the sales figure to something independent. What the auditor is doing at that stage is testing whether the reported figures reconcile to the books at all. The answer you give here largely determines how long the audit runs. A reconciliation that explains the difference between the bank, the books and the return closes most of the opening questions. A box of invoices with no reconciliation guarantees more of them.
Nearly always on documentation rather than on principle. A credit has to be supported by a record showing who supplied you, that the supplier was registered, what was supplied and that tax was charged — and that support has to exist for the claim, not be assembled afterwards. Common failures are invoices naming a trading style rather than the registered supplier, statements that show an amount but not the tax, and internal records where the supplier document was never obtained. The entitlement is usually real. The evidence is what is missing, and the credit is denied for that alone.
The periods under review are set out in the opening letter, and that is the scope until something changes it. What extends an audit is usually what the audit finds: an unexplained difference in one period is a reason to look at whether the same treatment ran through earlier ones. So the control you have is not procedural, it is evidential. Questions answered completely, with the reconciliation attached, close the period they relate to. Questions answered partly tend to be repeated across more periods. Where an extension is proposed, ask what specifically prompted it and answer that.
The first question is not the rate, it is the place of supply. Which tax applies to a sale depends on where the supply is treated as made, and that is determined by rules about the customer, the property or the service — not by where your business happens to be. Getting it wrong usually means a whole class of sales was treated consistently and consistently wrongly, which is easier to identify and correct than scattered errors. The exposure is the tax that should have been collected; whether it can be recovered from the customer afterwards is a commercial question rather than a tax one.
The information powers are wide and refusing outright is rarely useful. But a request can be clarified, and it is worth doing. Asking what a document is being sought to establish often narrows it substantially, and it lets you answer the underlying question directly. Handing over raw data without a reconciliation is the common mistake: the auditor then builds their own view of your figures, and you spend the rest of the audit responding to it. Produce what has been asked for, produce it in a form you have reconciled, and keep a record of everything sent.
Yes, and that stage is the most useful point in the whole process. A proposal sets out what the auditor intends to assess and why, which is the first time you see the reasoning rather than the questions. Written representations answering that reasoning, with the supporting records attached, are considered before anything is assessed. Arguments made later are made against an assessment that already exists, which is a harder position to argue from. If the proposal misstates a fact, say which fact and evidence the correction, rather than disputing the conclusion in general terms.
Missed years are handled as one package, not one at a time, because the route chosen for the first year determines the relief available for the rest. Each country has a disclosure or relief programme with its own conditions, and entering the right one — before the authority contacts you — is usually what keeps penalties down. Filing quietly outside a programme forfeits that protection. See catching up on missed returns.
It depends on the country, and a day count is only ever the start. Many use a threshold in a tax year, some also look at averages across several years, and some have no day test at all and decide on where your home and life are. Two countries can both conclude you are resident, which is what the treaty tie-breaker exists to settle. Counting days without checking the tie-breaker is how people end up filing as resident nowhere. See the residency tie-breaker.
Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.
