Senior Consultant · International Tax, Cross-Border Tax & Transfer Pricing · Legal Quotient Consultants
Big 4 international tax and transfer pricing, qualified in three countries
CPA (Canada), CPA (USA), CA (India)
Kulvinder Makkar works on international tax and transfer pricing at Legal Quotient Consultants, from Toronto. He is qualified in Canada, the United States and India, and his name was entered in 2024 in the Register of Members of Ontario's provincial accountancy regulator.
He came to this work through the Big 4: three years in transfer pricing at Deloitte in the Delhi area, then three years in international tax at Ernst & Young. His skills run across corporate and individual taxation, transfer pricing, international tax, corporate finance and accounting.
- Toronto
- Ex Deloitte and EY
- Canada, USA and India qualified
Areas of expertise
Transfer pricing
Intercompany pricing across Canada, the United States and India.
International tax
Corporate and individual files taxed in more than one country.
Corporate finance and accounting
The numbers the tax position rests on.
Qualifications
Canadian professional accounting designation
Qualified through the Canadian accounting profession's national certification programme and admitted to membership by a provincial regulatory body.
United States accounting designation
Passed the uniform accountancy examination used across the United States and certified by a US state board of accountancy.
Chartered Accountant (India)
Member of The Institute of Chartered Accountants of India (ICAI), the statutory body that regulates the chartered accountancy profession in India. Membership follows the Institute's examinations and a period of practical training.
Ontario register
Entered in 2024 in the Register of Members of Ontario's provincial accountancy regulator.
Big 4 experience
- Ernst & Young — International Tax (2014–2017) — international tax work in the Big 4.
- Deloitte — Transfer Pricing (2011–2014) — transfer pricing in the Greater Delhi Area.
What Kulvinder handles
Intercompany pricing files
the policy, the benchmarking and the documentation for groups with entities in Canada, the United States and India.
Treaty positions
corporate and individual files taxed in more than one country, and the treaty relief between them.
US and Canadian corporate tax
the returns and the cross-border reporting a group with entities on both sides of the border has to file.
Who Kulvinder works with
Multinational groups
Groups with related companies in two or more countries that need a pricing policy and the file to support it.
Indian and Canadian subsidiaries
Local companies owned from abroad, where the intercompany charges are the first thing a tax officer asks about.
Businesses with US operations
Canadian and Indian companies with a US subsidiary or US customers.
Speaking
Kulvinder has spoken to the ICAI Michigan and Ohio Chapters on U.S. Transfer Pricing: Trends and Insights, on recent developments in US transfer pricing and the cross-border questions they raise.
Disclosures
Professional status. The designations on this page are Kulvinder Makkar's own, held personally. Legal Quotient Consultants is not a licensed public accounting firm in Ontario, and nothing here says otherwise.
Scope. This practice prepares and files tax returns and supporting documentation, and represents clients with the revenue authorities. It does not perform audit or assurance engagements.
General information. Nothing on this page is advice for a particular situation. Book a consultation and the position is worked out on the facts of your file, with the fee agreed in writing before any work starts. Call +1 (416) 619-0068.
Profile last reviewed September 2026.
Cross-border tax case studies
Selling Into the US Without an Entity, and Filing in Several States
State obligations are set by each state, and a treaty does not reach them. The review measures activity against each state's own thresholds and separates the states where registration is required from the ones where it is not.
Read how this one runsA US LLC Owned From Canada
The 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 runsWithheld at the Statutory Rate When a Treaty Rate Applied
Where withholding has already gone out at the full domestic rate, the treaty rate is recovered rather than applied. The file establishes entitlement for each payment, then puts the documentation in place so the following year runs at the correct rate from the start.
Read how this one runsWintering in the US Long Enough to Become a US Filer
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 runsA Secondment Whose Paperwork Decided the Tax
Who employs, who directs and who bears the cost are the facts a treaty article turns on, and an assignment letter is where they are recorded. Drafting it with the tax position in view prevents an argument later.
Read how this one runsThe Same Income Taxed Twice on Paper
Relief usually exists and is lost to sequence: one country taxes at source and the other credits it, and preparing them in the wrong order claims a credit against a figure nobody has computed.
Read how this one runsA Family Trust Abroad With Reporting on Both Sides
A trust settled in one country and a beneficiary living in another produces reporting for the trust, the settlor and the beneficiary, on different forms and different dates. The engagement maps who files what before anything is prepared.
Read how this one runsThe Year of Leaving India
The departure year carries a transition status with its own treatment of foreign income, and the position for the following years follows from how it is set. Getting the first year right saves arguing about the rest.
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
- 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
Holding structures live or die on treaty access, beneficial ownership and substance — the MLI's principal-purpose test now sits over every arrangement.
A holding structure is only as good as its reporting. Foreign affiliates, accrued passive income and distributions each carry their own return, and the penalties on those attach to the form rather than to any tax being owed — so a structure that saves tax can still cost money if the information returns are late.
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
