The adviser who would review your file — what they are qualified in, the memberships you can check, and how to reach them today.
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.
Below: how the practice runs, what clients ask first, two worked files with their numbers, the process end to end, and the published fee.
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. That is the practical value of a specialist here: not better arithmetic, but knowing which of several possible rules governs raghav gupta — international tax before the return is built on the wrong one.
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.
Every one of those is a question we answer weekly. They arise because two tax systems were written independently and neither was designed with the other in mind. See also credentials & memberships.
The same point, with figures rather than adjectives.
Take C$104,000 of income taxed in both countries. Assume the other country charged 19% on it and the home country would charge 39% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$104,000 |
| Tax paid abroad (assumed 19%) | C$19,760 |
| Home tax on the same income (assumed 39%) | C$40,560 |
| Credit available (lesser of the two) | C$19,760 |
| Home tax still payable | C$20,800 |
The credit absorbs C$19,760 and leaves C$20,800 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. Your version of this table is the useful one, and it takes a short call and a document pack to produce.
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.
Worked through with figures, the mechanism looks like this.
Take C$143,000 of income taxed in both countries. Assume the other country charged 27% on it and the home country would charge 35% on the same amount.
| Item | Amount |
|---|---|
| Income taxed in both countries | C$143,000 |
| Tax paid abroad (assumed 27%) | C$38,610 |
| Home tax on the same income (assumed 35%) | C$50,050 |
| Credit available (lesser of the two) | C$38,610 |
| Home tax still payable | C$11,440 |
The credit absorbs C$38,610 and leaves C$11,440 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.
If that describes your position, the next step is a short call — not a form.
Read and approved for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.
Readers arrive here searching for international tax questions, and raghav Gupta 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.
People also search for: tax systems · the tax experts · what is price transfer · 2024 tax information · declare foreign assets.
Someone moved partway through a year and had income on both sides of the move. The work began by establishing when residence actually changed, because everything else follows from that date and it is a question of facts rather than of travel documents. The two returns were then prepared together rather than in sequence, so the income split and the relief claimed on one side match what the other side reports. The engagement produced a pair of returns that agree with each other, and a written note of the position taken on the date with the evidence for it.
A non-resident had tax withheld on income arising in a country they do not live in. Withholding of this kind is often applied to a gross amount rather than to the profit, so it routinely exceeds what is finally owed, and the only way to establish the real figure is to file. The work was to gather the costs that reduce the taxable amount, evidence them to the standard a reviewer expects, and file the return that computes the liability properly. The engagement produced a filed return and a claim for the excess that had been held at source.
The client had held accounts outside their country of residence for years and had assumed that reporting the income settled everything. It does not: the account itself is reportable separately from the income it produces, under rules with their own tests and their own filings. The work was to establish which accounts met the test in which years, gather the statements to support them, and prepare the reports alongside the returns. The engagement produced a complete set of filings and a standing checklist the client uses each year without needing to ask again.
A company was about to make a regular payment to a related party in another country and asked what rate to withhold. The prior question was what the payment was: the characterisation decides which rule reaches it, and the parties' own invoice description binds nobody. The contract and the actual dealings between the two companies were read before any rate was discussed. The engagement produced a written characterisation with the reasoning behind it, the withholding treatment that follows from it, and wording for the agreement that matches what is actually happening.
The employer had one arrangement covering everybody and wanted confirmation it was right. It was not so much wrong as undifferentiated: the answer depends on where each person is physically working, what their contract says and which entity bears their cost, and those differed across the group. Each employee was tested separately. The engagement produced remittances corrected going forward, a schedule of the historic position for the employer to take advice on, and a test their own staff apply when the next person moves.
A client brought a return prepared elsewhere for a view, expecting to be told it was wrong. Read against the documents, the position taken held up, including one treatment that looked unusual and turned out to be the correct reading for that year. The useful output was not a new filing but a written note of why the position stands and what would have to change for it to stop standing. The client kept it for the file. Telling somebody that their existing adviser got it right is part of the work.
Reasonable cause is a documented story with dates, not an assertion of good intent. The engagement assembles what the client actually knew and when, and puts the sequence in writing alongside the filings it explains.
Read how this one runsA US citizen resident in Canada, taxed in full on both sides because each return was prepared without the other in view. Deciding which country has the first right to the income, then claiming relief on the second return in the right order, is what stops the same dollar being taxed twice.
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.
A named adviser, and you are told who before the work starts rather than finding out from a signature afterwards. On this site every statutory page carries the name of the person who reviewed it and the date, linked to that person's page, so the claim is checkable rather than decorative. The practical consequence for your file is that there is somebody to ring with a question about a judgement in it, and somebody who answers for that judgement if it is ever queried. If you want to speak to them before you engage, ask. The number is +1 (416) 619-0068.
The arithmetic is the same. What differs is knowing which country's rule governs a situation before the return is built on the wrong one, and that judgement comes from having filed the same shape of file repeatedly rather than from reading about it. A general practice will handle a domestic return well, then meet a foreign account, a payment to a non-resident or a person who moved mid-year and have to work it out from first principles. Working it out from first principles is fine. Doing it on a live file against a deadline is where the avoidable errors come from.
Yes. The conversation before an engagement is the one that decides the scope, and the scope decides the fee, so it is better had with the person who will do the work than with somebody relaying it. Bring the facts rather than the conclusions: which countries, which years, what has already been filed in each, what has changed recently and what documents you hold. That is enough for an honest view of whether there is work to do. If there is, the fee is agreed in writing before it starts. The number is +1 (416) 619-0068.
Files with more than one country in them, in a few recognisable shapes. People who have moved and need the year of the move handled properly in both places. People who stayed put but hold accounts, property or a business abroad and have reporting to do because of it. Non-residents with income arising in a country they do not live in, where tax is often withheld at source on a basis that has little to do with what is finally owed. And companies making payments across a border, where the characterisation of the payment decides the treatment. Work outside those shapes is referred on.
Ask for the professional body they are registered with and the country it is in, then check with that body rather than with the firm. Ask what they have filed of the shape you need, and listen for whether they describe the mechanism or the service. Ask who reads their work before it goes out. A page carrying a person's name and a review date is a claim that can be tested, which is the reason for putting it there; a page that says a team reviewed it is a claim that cannot be tested at all.
Reads it, and can send it back. A sign-off that follows automatically from preparation is a formality, and everybody involved knows it. The reading works from your facts forward to the return rather than skimming the return for something that looks odd, because the errors worth catching in cross-border work are the ones where every figure is correct and the judgement underneath is not — income put in the right year on one side and the wrong year on the other, or relief claimed on a basis the documents do not support. Where the reading raises a question, the file waits.
As a sequence, stopping at the first test that gives an answer: where you have a permanent home available; if in both or neither, where your centre of vital interests is; then habitual abode; then nationality; and if all of those tie, the two tax authorities decide by agreement. It is evidential rather than elective — you do not choose your treaty residence, you demonstrate it, which makes the record of homes, family and time the substance of the claim. See tie-breaking dual residency.
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.
