The foundations behind every other topic on this blog: sourcing rules, the difference between a tax and a filing obligation, why currency conversion dates matter, and the order in which two returns should be prepared so that credits flow correctly. Read these before the specialist guides.
Cross-Border Basics — 7 in-depth guides
Are Taxes Higher in Canada Or UK
Are taxes higher in Canada or UK. How it actually works, what the relief requires, and the mistakes that cost the most — answered properly rather than guessed.
What Is Cross Border Tax
What is cross border tax — the mechanism, the paperwork sequence, and the errors we correct most often, with every variant of the question answered in one guide.
What Is International Tax
What is international tax. How it actually works, what the relief requires, and the mistakes that cost the most — answered properly rather than guessed.
Is Canadian Income Taxable in the US
A practitioner's guide to is Canadian income taxable in the US: the rule that decides it, the claims that make it real, and the quick answers to every version of the question.
What Is OECD Pillar 1
What is oecd pillar 1. How it actually works, what the relief requires, and the mistakes that cost the most — answered properly rather than guessed.
Do Canadian Companies Have to Pay US Sales Tax
A practitioner's guide to do Canadian companies have to pay US sales tax: the rule that decides it, the claims that make it real, and the quick answers to every version of the question.
What Is BEPS OECD
What is beps oecd — the mechanism, the paperwork sequence, and the errors we correct most often, with every variant of the question answered in one guide.
Other topics Estates, Gifts & Trusts, Withholding & Forms, Tax Treaties, Foreign Property, Business & Structure.
Files that look like this one
New cross-border family's residence and sourcing rules explained on their facts
A newly cross-border family needed the basic residence and sourcing rules for both countries explained against their specific facts before any return was prepared for the first time. We reviewed the family's actual living and working arrangement and set out which country's rules governed each source of their income.
US-bound sales split correctly between sales tax and income tax rules
A Canadian company selling into the United States needed to understand which of its receipts fell under sales tax rules and which fell under income tax rules, since the two systems apply on entirely different bases. We reviewed the company's revenue streams and separated the two regimes' obligations correctly.
Multinational's Pillar exposure assessed against the rules already in force
A business affected by the shifting international rules on where large multinational profit gets taxed needed its own exposure assessed against the rules that were already in force for a business of its size. We reviewed the company's structure against the current rules and confirmed which provisions actually reached it.
A Penalty Argued on the Facts Rather Than the Form
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 Margin Defended With a Benchmarking Set That Fits the Facts
A comparables set is only as good as the screening behind it, and a rejected set takes the margin with it. The study selects the tested party first, screens on function rather than on industry code, and records why each comparable survived.
Read how this one runsA Company Abroad Owned by a US Person
A business incorporated where the owner lives is a foreign corporation to the IRS, with a reporting package of its own and schedules that need local accounts restated. Classification comes first, because it decides what is reportable and when profits are taxed.
Read how this one runsA Foreign Property Form Filed Late, With Penalties Running Daily
The foreign asset return carries a penalty that accrues per day rather than per return, so the exposure grows quietly. Relief is discretionary and it is granted on the reasons given, which means the request is the work rather than the form.
Read how this one runsA US Citizen Settled in India, Filing on Both Sides
Residence in India and citizenship in the United States produce two annual returns for one income. The order decides the credit, and the Indian financial year and the US calendar year have to be reconciled before either is prepared.
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
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- 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
