Udit Gupta
Cross-Border Tax Expert
CA (ICAI), In-Depth Tax Trained
Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.
Our tax experts
The adviser who would review your file — what they are qualified in, the memberships you can check, and how to reach them today.
- 15+Years of cross-border experience
- 18,000+Clients served
- 5.0Google rating
- 4Global offices — India, USA, Canada & UAE
In short
Rule 5 of how we publish: every statutory page on this site carries a reviewer's name and the date it was reviewed, linked to that person's page.
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.
How we publish, and who signs off
Rule 5 of how we publish: every statutory page on this site carries a reviewer's name and the date it was reviewed, linked to that person's page. This is that page. Tax content is judged on who wrote it, and it should be.
Everything else on this page follows from this. 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.
What clients ask about the person reviewing their file
I want to know who signs off on the advice I am relying on.
I need someone who has actually filed in both of my countries, not read about it.
I want the person reviewing my file to be reachable.
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 contact US — 24-hour helpline.
The numbers, end to end
Numbers make this concrete, so here is the same rule applied to a set of figures.
Credit relief on one stream of income
Take C$94,000 of income taxed in both countries. Assume the other country charged 19% on it and the home country would charge 42% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$94,000 |
| Tax paid abroad (assumed 19%) | C$17,860 |
| Home tax on the same income (assumed 42%) | C$39,480 |
| Credit available (lesser of the two) | C$17,860 |
| Home tax still payable | C$21,620 |
The credit absorbs C$17,860 and leaves C$21,620 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. Your version of this table is the useful one, and it takes a short call and a document pack to produce.
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.
What this looks like with numbers
The arithmetic is more persuasive than the description, so:
Credit relief on one stream of income
Take C$125,000 of income taxed in both countries. Assume the other country charged 22% on it and the home country would charge 40% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$125,000 |
| Tax paid abroad (assumed 22%) | C$27,500 |
| Home tax on the same income (assumed 40%) | C$50,000 |
| Credit available (lesser of the two) | C$27,500 |
| Home tax still payable | C$22,500 |
The credit absorbs C$27,500 and leaves C$22,500 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.
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.
The four steps
- 1A call to our 24-hour helpline to establish the facts and the dates that matter
- 2A written scope and a fixed fee before any work starts
- 3Preparation, then a named reviewer's sign-off before anything is filed
- 4Filing, then payment — after you have seen and approved the result
- Fixed fees agreed before any work starts, so the number in the quote is the number on the invoice.
- Authorisation with each authority, so we see the assessments and slips directly rather than asking you for them.
- Documents move through one secure portal, and you can meet us in person at any of our offices.
Your next step
If that describes your position, the next step is a short call — not a form.
The five practitioners, and what each of them carries
Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.
Abhinav Gupta
Canada Tax / International Tax
Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing
Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.
Raghav Gupta
International Tax
International Tax, Transfer Pricing Specialist
Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.
Anmol Mittal
Canada and US tax
CPA Canada, CPA USA, CA (ICAI)
Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.
Vinayak Indolia
CFO advisory
CPA, CA. Fractional CFO and Senior Advisory Specialist
Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.
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.
Where the tax experts comes into this file
Read this page for the tax experts. It works through our tax experts from the beginning — whether it applies to you at all, what has to be filed if it does, and what the engagement costs, priced up front.
People also search for: international tax planning · what is price transfer.
What these engagements turn on
Case study 1
A file split across desks and put back together
An individual with a foreign account reporting obligation also owned a share of a company abroad. Those are different bodies of knowledge, so the personal reporting and the corporate analysis were prepared at separate desks and then reconciled before anything was filed, because the two have to describe the same entity in the same way. The reconciliation found a difference in how the shareholding had been characterised, and it was settled before submission. The engagement produced a personal return and a set of reports that agree with each other and with the corporate position behind them.
Case study 2
An engagement reassigned when a third country appeared
The scope conversation had covered two countries. Once the documents arrived a third appeared, in the form of an employer entity nobody had mentioned, and the analysis moved with it. The file was reassigned to the adviser who handles that jurisdiction, and the work already done was handed over rather than repeated, with a written note of the positions taken so far and the questions still open. The client was told of the change and the reason on the day it was made. Allocation by subject only works if it is revisited when the subject turns out to be different.
Case study 3
A second adviser brought in for the transfer pricing question
The adviser holding the corporate file knew the group and its returns, but not the documentation standard the second country expects for dealings between related companies. Rather than the whole engagement moving, a second adviser took that part, and the split was written down so each knew what the other was relying on. The functions and risks were described once and used by both. The engagement produced a corporate return and a documentation file that rest on the same account of what the two companies actually do for each other.
Case study 4
A handover between advisers that did not restart the questions
An adviser left the subject area between one filing season and the next. The client's file carried the positions taken, the basis recorded for each and a list of things to watch in the following year, so the new adviser read into it rather than interviewing the client again from the beginning. An open question from the previous year sat in that list and was dealt with early instead of being rediscovered late. The engagement produced the year's filings without the client being asked for anything they had already provided.
Case study 5
A question answered by saying it was outside our area
A prospective client asked about a filing obligation in a country this practice does not work in. The useful answer was to say so, describe in general terms what the obligation appeared to turn on, and point them toward someone who files there. No engagement was written. What they left with was enough to ask the right question of the next adviser, which is worth more than a confident answer from somebody reading those rules for the first time.
Case study 6
A payroll arrangement reviewed by the person who runs those files
An employer's arrangement had been looked at by a generalist and appeared broadly right. It went to the adviser who handles payroll across borders for a second reading, and the question that came back was where each employee was physically working rather than where the contract said they were. On that basis the withholding differed for part of the workforce. The engagement produced corrected remittances going forward and a written test the employer's own staff apply when somebody moves, so the same question is not reopened from scratch each time.
Case study 7
A Pricing Study That Started With Who Does What
Functions, assets and risks decide which entity should earn the return, and the method follows from that rather than the other way round. Getting the sequence backwards is how a study fails on its first question.
Read how this one runs
Case study 8
Years Filed Quietly, and What That Cost
Posting missing returns without taking a view on the route gives up the certification-based protection and can itself be read as an indicator. The first task on these files is mapping which years remain eligible for which route.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.
U.S. & Cross-Border Tax Returns
Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.
Expat & Emigration Tax
The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.
Non-Resident Canadian Tax
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.
Transfer Pricing & BEPS
Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.
Tax Treaties & Withholding
Relief is only as good as the paperwork claiming it — we build treaty positions that survive review on both sides.
Cross-Border Estates & Trusts
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Global Investments & Reporting
Information returns carry the sharpest penalties — $25 a day whether or not any tax is owing. We keep them clean and on time.
Cross-Border Corporate Tax
Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.
India Tax for NRIs & Returning Residents
The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.
Canadian Tax with a Foreign Element
Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.
UAE Tax for Expats & Their Home Country
A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Who We Serve:
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Who We Serve:
Professional Services Firms
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Who We Serve:
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Who We Serve:
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Who We Serve:
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Who We Serve:
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Who We Serve:
Investment Funds & Holding Companies
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
Who We Serve:
Our tax experts — questions we are asked
How is the fee actually set?
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.
Can you work with my existing accountant?
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.
How do I know my accountant has actually filed in both countries?
Ask which countries they file in themselves and which they refer out, and ask it as two separate questions. Plenty of practices advise on a foreign return and then hand the filing to someone abroad, which is a perfectly honest arrangement as long as you know it is happening — because the person who advises and the person who files have to agree on what the return says. Then ask to see a file of the shape of yours and read how it was handled. A practice that files in a country routinely will describe the mechanics without having to look them up.
What should I look for in a cross-border tax adviser?
Someone who starts with your facts rather than with a product. The first thing a cross-border file turns on is residence, and residence is a question about where your life actually is, not about which passport you hold or where your employer sits. An adviser who asks about the home, the family, the days and the contracts before quoting is doing the work in the right order. The second thing to look for is a named person who will answer for the file. The third is a fee agreed in writing before anything starts, so the scope conversation happens while it can still change something.
Can I choose which adviser handles my file?
You can ask, and where the specialism fits you will get who you ask for. What we will not do is put a file on a desk because the client liked that person's page, when the substance sits with somebody else. Files here are allocated by subject rather than by rota: a corporate cross-border payment, a payroll spread over two countries and an individual's foreign account reporting are different bodies of knowledge. You are told who has your file and who is reading it before the work starts, and if the allocation changes mid-engagement you are told that too, with the reason.
Will the same person handle my return next year?
Usually, and the file is written so that it does not matter if they cannot. Continuity in this work comes from the record rather than from memory: the positions taken, the basis for each, the documents relied on and the things to watch for next year are written into the file at the time. That is why a handover between advisers does not mean starting the questions again from the beginning. Where a person does change, you are told who has taken it over before the next engagement letter goes out, not after the return has been prepared.
Does anyone here prepare US and Canadian returns together?
Yes, and treating them as one exercise rather than two is the point. Filed separately by two firms, the common failure is that each return is internally correct and the pair contradict each other — income recognised in different years, relief claimed on one side that the other side's treatment does not support, an entity characterised one way here and another way there. Prepared together, the order of work is settled first: which country has the first claim on which income, and what the second return then has to reflect. That order is the part that has to be right.
What can I verify about an adviser before I engage them?
More than most people check. Ask for the person's name in writing, ask which professional body they are registered with and in which country, then verify it with that body directly rather than with the firm. Ask what they have filed of the shape you need, and listen for whether they describe the mechanics or the service. Ask who reads their work before it goes out. Every statutory page on this site carries the name of the person who reviewed it and the date, linked to that person's page, which is there so the claim can be checked rather than taken on trust.
How does cross-border tax planning work?
It starts with facts rather than structures: which countries have a claim on you, what each one taxes, and where the two overlap. From there the decisions are about order and timing — which country taxes first, where relief is claimed, and whether a filing or a certificate has to be in place before money moves rather than after. Most of the value is in the sequencing, because relief claimed late is usually relief recovered slowly. See international tax planning.
What happens if I have not filed for several years?
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.
