Where a company is managed, where it sells and where its owners live can be three different places. These guides look at how a branch differs from a subsidiary, when a foreign business acquires a taxable presence, how profits move between related companies, and what an owner-manager should decide before the first invoice crosses a border.
Business & Structure — 3 in-depth guides
What Is Transfer Pricing in Accounting
What is transfer pricing in accounting. How it actually works, what the relief requires, and the mistakes that cost the most — answered properly rather than guessed.
What Is GILTI Income
A practitioner's guide to what is GILTI income. The rule that decides it, the claims that make it real, and the quick answers to every version of the question.
How to Calculate GILTI Inclusion
How to calculate gilti inclusion — the mechanism, the paperwork sequence, and the errors we correct most often, with every variant of the question answered in one guide.
Other topics Canada–US Corridor, Tax Treaties, Retirement & Pensions, Cross-Border Basics, Estates, Gifts & Trusts.
Cross-border tax case studies
Related-party group's master file aligned with every local file
A group with related companies in different countries needed its master file and local file materials aligned so neither told a different story about the same intercompany terms. We reviewed both sets of documentation, resolved the inconsistencies between them, and produced a set of files that agreed with each other.
Foreign corporation shareholder's structure reviewed for GILTI treatment
A closely held foreign corporation's shareholder needed their structure reviewed to understand how the GILTI regime would treat the entity's income going forward as the business grew. We reviewed the entity's income composition and set out how the regime's inclusion mechanics would apply to the shareholder's actual position.
New intercompany service arrangement priced before the first invoice
A business restructuring its cross-border operations needed the pricing on a new intercompany service arrangement documented before the first invoice under the new structure was issued. We prepared the pricing analysis and supporting documentation ahead of the first transaction rather than after the arrangement was already running.
A US LLC Owned by a Canadian, Taxed Twice by Design
The two countries classify an LLC differently, so the credit relief that ought to apply frequently does not. The engagement looks at whether the structure can be changed, and where it cannot, at how to make the credit work.
Read how this one runsA Shareholder Loan Across a Border at No Interest
An interest-free loan between related companies is priced as if it carried interest, and in some cases a deemed benefit follows as well. The file sets a rate against the borrower's own credit profile and documents the terms that support it.
Read how this one runsA Group File That Had to Describe the Whole Group
The master file is a picture of the business rather than of one company, and it has to agree with what each local file says. Assembling it surfaces inconsistencies between entities that nobody had compared.
Read how this one runsA Retirement Plan That Grows Tax-Deferred in Only One Country
Cross-border retirement accounts are recognised by treaty, but the deferral usually has to be elected rather than assumed. The engagement checks whether the election was made, makes it where it was missed, and reports the account on whichever side requires it.
Read how this one runsA Clean History Used to Remove a First Penalty
An administrative waiver can remove a first failure where the filing and payment record supports it, and it is spent once used. Whether to claim it now or keep it for a heavier year is a judgement made with the whole file in view.
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
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.
- 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
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
