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.
Below: how the practice runs, what clients ask first, two worked files with their numbers, the process end to end, and the published fee.
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.
Here is the part that decides your answer. That is the practical value of a specialist here: not better arithmetic, but knowing which of several possible rules governs how the voluntary disclosures programme works before the return is built on the wrong 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.
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 same point, with figures rather than adjectives.
Take C$151,000 of income taxed in both countries. Assume the other country charged 25% on it and the home country would charge 41% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$151,000 |
| Tax paid abroad (assumed 25%) | C$37,750 |
| Home tax on the same income (assumed 41%) | C$61,910 |
| Credit available (lesser of the two) | C$37,750 |
| Home tax still payable | C$24,160 |
The credit absorbs C$37,750 and leaves C$24,160 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.
These amounts illustrate the mechanism only. The rates and thresholds are assumptions of the example, not your numbers: each is checked against the issuing authority for your specific tax year before any return is filed.
Put numbers against it and the shape of the answer is obvious.
Take C$159,000 of income taxed in both countries. Assume the other country charged 21% on it and the home country would charge 41% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$159,000 |
| Tax paid abroad (assumed 21%) | C$33,390 |
| Home tax on the same income (assumed 41%) | C$65,190 |
| Credit available (lesser of the two) | C$33,390 |
| Home tax still payable | C$31,800 |
The credit absorbs C$33,390 and leaves C$31,800 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.
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.
If a letter prompted this, bring the letter — it usually contains the answer to half the questions.
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.
Readers arrive here searching for international tax accountant, and how the Voluntary Disclosures Programme works is what the page is about. Below: who it catches, what has to be filed, and what it costs — quoted in writing, before anything is done.
The client held accounts abroad that had never appeared on a return, and had recently been asked by the bank to confirm a tax residence. Nothing had arrived from the authority, so the first step was to establish that and to record the date the file was opened. The years were then rebuilt from statements obtained directly from the institutions, with one conversion basis applied consistently across all of them. The engagement produced a complete set of filings for the years affected, an application setting out how the omission arose, and an estimate of the tax, paid on submission.
The client arrived with a letter they had been told was routine and wanted a disclosure prepared. Reading it, and the correspondence behind it, showed that action had already begun on the very information the client intended to disclose, which is the one fact the programme does not survive. No application was made. The returns were prepared and filed on their merits instead, the client's cooperation was documented from first contact onwards, and relief was requested through the route that remained open. The engagement produced filed years, a written record of the chronology, and no reliance on a condition that could not be met.
The executor discovered income the deceased had received abroad for years and never reported, and had to decide what to do before distributing anything. The first question was authority: who may make a disclosure for a person who has died, and what the executor's own exposure is if the estate is distributed first. The years were reconstructed from the institutions rather than from the papers in the house, and the estate's own filings were aligned with them. The engagement produced a disclosure made by the party entitled to make it, filings for every year affected, and a distribution held until the position was known.
The company had stopped trading, the director assumed the obligation stopped with it, and several years of returns had never been filed. Establishing what the company had actually done in each year came first, because a dormant year and a year with a single transaction are filed differently. Financial statements were reconstructed from bank records, the returns were prepared in sequence so that balances carried forward properly, and the application described that sequence plainly. The engagement produced a filed set of corporate years, a disclosure application explaining them, and a company that can now be wound up or revived on a known position.
The client had filed conscientiously where they lived and had never filed where they remained a citizen, having been told that no tax would be due there. Tax due and filing required are separate questions, and the second had been outstanding for years. The residence position was fixed first, then a return was prepared for each year with the foreign income and the credits for tax already paid abroad. The engagement produced a complete set of filings, an application setting out how the misunderstanding actually arose, and a client whose two countries' records finally describe the same person.
The client had submitted a disclosure themselves, covering the years for which they still held statements, and had then been asked for more. Completeness is a condition rather than a preference, and a package that stops where the paperwork stops invites exactly that question. The missing years were reconstructed from the institutions, the figures already submitted were checked against them and two were corrected, and the outstanding correspondence was answered in one reply rather than several. The engagement produced a complete record for every affected year and a written explanation of why the original submission had stopped where it did.
A voluntary disclosure has to be genuinely voluntary — once a letter arrives, the route usually closes. The engagement establishes whether the programme is still available, prepares the years, and puts the relief request in with the filing rather than after it.
Read how this one runsThe heaviest exposure on a cross-border file is often a disclosure form rather than the tax. Where the return itself was right, the procedures for late information returns turn on a reasonable-cause narrative with dates and documents behind it.
Read how this one runsAll case studies — every published engagement in one place.
Strategy and compliance for income, assets and families spread across borders.
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.
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 letter is usually the problem. The programme is built around the disclosure being voluntary, which means made before the authority takes action that would have reached the same information. Once enforcement activity has started against you, and in some circumstances against a related party or an entity you control, the disclosure is no longer voluntary and the application can be refused on that ground alone. Not every mailing is enforcement action, and the distinction matters enough to establish before you assume it either way. If you have had contact, keep the letter and ring before filing anything. +1 (416) 619-0068.
No. Relief under the programme is relief from penalties and, where it is granted, from part of the interest. The tax itself remains payable, and an application that ignores that is not complete. In practice the tax is the part you can plan for, because it is computed from the years being disclosed and can be quantified before anything is submitted. What cannot be quantified in advance is the relief, which is discretionary and decided by the authority on the facts presented to it. Anyone telling you the penalties will be waived before the package is even written is guessing.
All of them. Every year in which the information was wrong or missing, not a convenient subset. Completeness is one of the conditions, and a disclosure that stops at the years the client happens to remember is the commonest way a sound application fails. In practice, reconstructing the earliest years is the slow part: statements must be obtained, a currency conversion basis has to be applied consistently, and figures used in a later year must agree with the earlier ones. That work is done before the application, not after, because an amended figure afterwards invites the question of whether the original was complete.
You can discuss how the programme would apply to a set of facts before identifying yourself, which is useful for understanding the route but binds nobody. Nothing said in that conversation protects you, and time keeps running while it happens. Treat it as a way to find out whether your facts fit the conditions at all, meaning voluntariness, completeness, and the presence of a penalty that would otherwise apply, rather than as a form of protection in itself. If the answer is that they do fit, the sensible next step is assembling the years, because an application is only as good as the file underneath it.
The filings you made do not disappear. A refused application generally leaves the returns on record and the tax assessed, with penalties and interest applied as they would have been without the programme, and there is a review route where the refusal turned on how the facts were read rather than on the facts themselves. This is why the eligibility question is settled first. Submitting a package in the hope that the voluntariness test will be read generously is how people end up with all of the filing obligations and none of the relief. Where the conditions plainly are not met, other routes exist and are worth considering beforehand.
Payment of the estimated tax is expected as part of a complete application, and where the amount cannot be paid in full the request is made explicitly rather than left silent. Estimating it is therefore part of preparing the package and not an afterthought: the years are computed first, the figure is stated, and either the payment or the request accompanies the submission. The order matters. An application that arrives with the story but no numbers invites correspondence, and correspondence is where a file loses the one thing it was relying on, which is that it was complete when it was made.
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.
Yes, through more than one channel. The treaty has an exchange-of-information article that supports both routine and on-request exchange. Separately, an intergovernmental agreement has Canadian financial institutions identify US-reportable accounts and report them to the CRA, which passes them to the IRS, with the reverse flow for Canadian residents. Most other country pairs use the Common Reporting Standard for the same purpose. See FATCA reporting.
Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.
