Case study 1
Delay had lifted account balances and changed the penalty base
Years passed between the client first taking advice elsewhere and a submission being prepared, and in the meantime the unreported accounts had grown. Because the domestic charge is computed on the highest aggregate value of the unreported assets, the figure was not the one originally sketched for them. We rebuilt the balances by year and showed how the base arose. The engagement produced a documented valuation across the whole period and a submission whose penalty computation the client could follow.
Read how this one runs
Case study 2
Canadian balance owing charged at the higher rate during a US catch-up
While the domestic submission was being assembled, the Canadian side of the file had returns outstanding with tax to pay, and an earlier demand to file with a penalty charged on it put those years into the higher band. We established that history from the client's own notices, computed the Canadian exposure on the correct footing, and dealt with the known balance ahead of the remaining work. The engagement produced filed Canadian years, a checked penalty computation, and a reconciled cross-border position.
Read how this one runs
Case study 3
Notice arrived from the authorities midway through preparation
Work was well advanced when correspondence landed, which put the route itself in question rather than merely the timetable. We stopped drafting, established what the notice was and what it foreclosed, and set out the options that remained on that footing. The engagement produced a documented reassessment of route, a preserved record of everything prepared before the notice arrived, and a response made on the basis that actually applied rather than the one the file had assumed.
Read how this one runs
Case study 4
Nil tax across the years with the exposure sitting in asset values
The unreported income produced almost no tax, and the client had read that as meaning there was little to resolve. The domestic charge is driven by asset value, so the exposure sat somewhere the tax computation never showed it. We valued the accounts across the period, set the figure out plainly before anything was signed, and prepared the returns and reports. The engagement produced a penalty base with its workings and a submission the client entered with the cost understood.
Read how this one runs
Case study 5
Early years reconstructed where the bank records had gone
Statements for the oldest years were no longer available from the institution, and those were the years the valuation most needed. We worked from what could be obtained — later statements, correspondence, the client's own papers — documented the basis for each year's figure, and flagged where a value rested on inference rather than on a statement. The engagement produced a reconstructed valuation with its limitations recorded, and a submission that does not overstate the evidence behind it.
Read how this one runs
Case study 6
Accounts in two currencies valued on a consistent documented basis
The unreported holdings were denominated in different currencies, so the aggregate value depended on which conversion basis and which dates were used. We fixed one basis, documented it, applied it across every account and year, and made sure the returns, the reports and the certification all used the same figures. The engagement produced a conversion note explaining the method, a penalty base computed on it, and a package whose parts agree with each other.
Read how this one runs
Case study 7
Information Returns Missed Behind a Correct Return
The 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 runs
Case study 8
Documentation Requested, and the Deadline Is Not Extendable
Contemporaneous documentation has to exist by the filing deadline, not be assembled when it is asked for, and the penalty protection turns on that timing. The engagement produces the analysis for the year in question and puts a repeatable process behind the next one.
Read how this one runs
