Departure & Exit Tax — 2 in-depth guides
What States Have An Exit Tax
What states have an exit 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 Expatriate Tax
What is expatriate tax: how it actually works, what the relief requires, and the mistakes that cost the most — answered properly rather than guessed.
What these engagements turn on
A Residency Determination Review After Leaving the Country
Residence is decided on ties, not on a form, and the review asks for evidence of every one of them. The file assembles the ties that were severed and the ones that remained, and answers the questionnaire against the treaty rather than around it.
Read how this one runsLeaving Canada — the Bill You Get for Assets You Still Own
Emigrating triggers a deemed disposition of most holdings, which produces tax on gains never realised in cash. The file values the property, identifies what is excluded, and looks at whether security can be posted rather than the tax paid outright.
Read how this one runsA Foreign Affiliate Return Filed Years Late
The reporting obligation on a company held abroad runs separately from the corporate return and carries its own exposure. The work is reconstructing the surplus position across the open years before any filing goes in.
Read how this one runsA 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 runsAn Assignee Paid at Home and Taxable Away
Where pay stays on the home payroll but the tax arises elsewhere, a shadow run reports the second country's liability without duplicating the payment. Setting it up correctly is what keeps both sides reconcilable.
Read how this one runsSelling Into the US Without an Entity, and Filing in Several States
State obligations are set by each state, and a treaty does not reach them. The review measures activity against each state's own thresholds and separates the states where registration is required from the ones where it is not.
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 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 runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
U.S. & Cross-Border Tax Returns
Expat & Emigration Tax
Non-Resident Canadian Tax
Transfer Pricing & BEPS
Tax Treaties & Withholding
Cross-Border Estates & Trusts
Global Investments & Reporting
Cross-Border Corporate Tax
India Tax for NRIs & Returning Residents
Canadian Tax with a Foreign Element
UAE Tax for Expats & Their Home Country
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Professional Services Firms
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
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
