Case study 1
Multi-member LLC that believed it had nothing to file
Two people had registered a multi-member LLC for a venture that earned nothing in the US and had filed no partnership returns, on the understanding that a business with no US customers had no US return. Our work was to establish the entity's classification from its formation documents, confirm that the filing obligation rested on the facts about the entity rather than on tax being owed, and prepare the outstanding returns with allocations to each member. The engagement produced a filed set of partnership years and, for each member, a statement of their share they could take to their own adviser.
Read how this one runs
Case study 2
A non-US partner joining part way through the year
A partnership admitted a partner resident abroad during its financial year, which changed both who the international schedules had to describe and how the year's income had to be split between the period before and after admission. We set out the allocation method in writing before preparing anything, tested it against the partnership agreement, and then sourced the income by country so the incoming partner's share could be evidenced at home. The engagement produced a filed return whose allocation the new partner's own adviser accepted without a reconciliation exercise.
Read how this one runs
Case study 3
Dormant partnership brought back into the filing system
A partnership that had traded briefly and then gone quiet was still registered, still had partners in two countries, and had stopped filing on the assumption that a dormant business is invisible. We reconstructed each year from bank records and the partnership agreement, confirmed which years were genuinely nil and which were not, and filed the outstanding returns in order so the allocations ran consistently from one year to the next. The engagement produced a complete filing history and a written note of the facts supporting each year, which the partners could hand to their own advisers.
Read how this one runs
Case study 4
Sourcing disagreement between the partnership and a partner abroad
A partner's adviser in another country rejected the source given to part of their allocated income, which would have moved the relief available to them at home. Rather than restate the return to suit one partner, we documented how each class of income had been sourced, which records supported it, and where the two systems genuinely describe the same receipt differently. The engagement produced a written sourcing position for the partnership that survived the partner's home-country enquiry, and a schedule the partnership now reuses each year rather than reopening the argument.
Read how this one runs
Case study 5
Entity filing the wrong return for years after an election
A closely held business had elected corporate treatment years earlier, then changed advisers and quietly returned to filing partnership returns, so the entity was describing itself two ways in the same decade. We traced the election and the evidence that it had been made, established which return the entity was required to file for each year in question, and then corrected the years that did not match. The engagement produced one consistent classification, a filed set of returns on that footing, and a note on file explaining the history for anyone who examines it later.
Read how this one runs
Case study 6
Final partnership return on a wind-up across several countries
A partnership was closing and its partners were resident in different countries, each with its own year end and its own timetable for reporting a disposal. The order of work mattered more than the arithmetic: we settled the closing allocations first, then the sourcing, then prepared the final return so that each partner received figures they could file with rather than provisional ones they would have to amend. The engagement produced a final filed return, closing statements for every partner, and a short memorandum recording how the wind-up had been allocated.
Read how this one runs
Case study 7
Deemed Resident or Factual Resident — Not the Same File
The two statuses attract different returns, different credits and different provincial treatment, and the label is decided by facts rather than chosen. Establishing which applies is the work; the filing follows from it without argument.
Read how this one runs
Case study 8
Coming Back to Canada After Years Abroad
Returning restarts Canadian residence and re-values what you own on the day you arrive. Foreign pensions, employer plans and accounts opened abroad each land differently, and the reporting thresholds are tested against the whole portfolio rather than each account.
Read how this one runs
