What a page on this site is allowed to claim
Every page is researched against primary sources — the Income Tax Act, the CRA’s own publications and the treaty texts themselves — and is reviewed before it is published.
Where a rate, a threshold or a due date could not be confirmed in the authority's own material for the year in question, the page describes the mechanism and quotes no number. A confident wrong figure in a cross-border file becomes a penalty the client carries, so the rule is primary source or no figure — and when a figure does appear, the page says which tax year it belongs to.
Fees follow the same rule: pricing pages state the fee basis agreed before work starts, and nothing on the site advertises an outcome — a refund amount, a penalty reduction — that a reader's own file might not reach.
Who reviews it, and how pages are dated
Pages are reviewed before publication by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants — his professional memberships, with the registry numbers to check them, are on that profile. The review boxes at the foot of articles and answer pages name him for the same reason: a reader should always be able to see who stands behind a page.
Every page carries a modification date that comes from the page's actual content: it changes when the substance of the page changes, and it does not change when the page is merely rebuilt. A date on this site is a claim about the content, not a decoration.
Corrections
If something on this site looks wrong — a figure, a form number, a deadline, a description of how a rule works — tell us and we will check it against the primary source. If the page is wrong, we correct it and the page's modification date reflects the change. We would rather retract a number than defend it.
Send the page address and what you believe is incorrect to contact@lqconsultants.com, or call +1-416-619-0068 or +91-989-909-9030. You do not need to be a client.
What these engagements turn on
A stale rate caught before publication rather than after
A page drafted covering a specific filing threshold used a figure carried over from the previous tax year's material, and the review process against the current year's primary source caught the discrepancy before the page went live. The figure was corrected and the tax year it belonged to was stated explicitly, consistent with the standing rule that a number without its year is a number that becomes wrong without warning. Nothing was published until the source and the year matched.
A section number removed after it could not be verified against Justice Laws
A draft page cited a specific statute section supporting a described mechanism, and when the citation was checked against the primary legislative text directly, the section did not say what the draft claimed. Rather than publish an unverified citation, the section number was removed and the page instead described the mechanism itself without attaching a number that could not be confirmed — the standing rule that a mechanism can be described without a citation, but a citation must be right or absent.
An outcome claim reworded after review flagged it as something a reader cannot rely on
A draft description of a service mentioned an outcome — a specific kind of result a filing had achieved — in a way that read as something every reader could expect rather than describing what the engagement itself involved. Editorial review flagged that an outcome depends on facts unique to each file and cannot be advertised as a standing promise, and the page was rewritten to describe the process and the basis for the fee rather than a result no reader's own facts had been tested against.
A correction made after a reader pointed out a superseded rule
A reader wrote in noting that a page's description of a filing rule reflected an earlier version of the law that had since been amended. The claim was checked against the current primary source, confirmed to be outdated, and the page was corrected with the current position and the tax year it took effect. The correction was made promptly rather than left pending, consistent with the standing editorial rule that a reader-flagged error is checked and fixed rather than defended.
Interest and Penalties Put to a Relief Application
Relief is discretionary and is decided on the circumstances that caused the delay, evidenced year by year. The application is built from the same chronology the filings rest on, so the two cannot contradict each other.
Read how this one runsA Home Kept in Canada After the Move Abroad
A dwelling left available is the tie the CRA weighs most heavily, and its treatment differs depending on whether it is rented at arm's length. The file settles the residence position first and the rental reporting second.
Read how this one runsA Certificate Obtained Before the Money Moved
An application for a reduced or nil deduction is made in advance and decided on the computed liability, not on the gross amount. Applying after the payment leaves a refund claim in place of a certificate.
Read how this one runsSocial Security Contributions Owed in Two Countries at Once
A totalization agreement assigns contributions to one system and exempts the other, but only against a certificate obtained in advance. Without it both sets come out of the same salary and neither is straightforward to recover.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- 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
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
