Retirement & Pensions

Pensions, registered plans and social security payments are taxed by the country that pays them, the country you live in, or both, depending on the treaty and the account. These guides explain how each type of retirement income is treated across a border and which elections keep the plan intact.

Retirement & Pensions — 2 in-depth guides

2026-06-12

Do Expats Get Social Security

Do expats get social security — the mechanism, the paperwork sequence, and the errors we correct most often, with every variant of the question answered in one guide.

2026-05-25

Does Dual Citizenship Affect Social Security Benefits

A practitioner's guide to does dual citizenship affect social security benefits: the rule that decides it, the claims that make it real, and the quick answers to every version of the question.

Other topics NRI & India, Residency & Status, Working Across Borders, Foreign Property, Tax Treaties.

← All cross-border tax guides

Cross-border situations we are engaged for

Case study 1

Treaty-allocated pension's elective filing considered before a deadline closed

A retiree receiving a pension under a treaty article that allocates taxing rights differently from employment income needed an elective filing considered before a deadline closed off the option entirely. We reviewed the article's election and confirmed it before the deadline, rather than leaving the flat withholding to stand.

Case study 2

Returning resident's foreign accounts revalued as of the arrival date

A person returning to Canada after years abroad needed their foreign accounts and pension plans revalued as of their arrival date and reported against the correct disclosure threshold. We revalued the holdings at arrival and confirmed which accounts crossed the threshold requiring disclosure.

Case study 3

Cross-border retirement account's deferral election confirmed rather than assumed

A person holding a cross-border retirement account needed to confirm whether the deferral the treaty allows had actually been elected, since the deferral is not automatic on either return. We reviewed the account's filing history and confirmed whether the election had been made, correcting the position where it had been missed.

Case study 4

A Pension Taxed Where the Treaty Did Not Intend

Pension and annuity articles allocate taxing rights differently from employment income, and a flat withholding often exceeds what a return would produce. The alternative filing is elective and has a deadline.

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Case study 5

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.

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Case study 6

A 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.

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Case study 7

A Canadian Property Sale Held Up for a Clearance Certificate

When a non-resident sells Canadian real estate the purchaser must hold back a portion of the price until the seller produces a certificate. The file applies for it on the correct basis and works to the closing date, because the holdback is released against the certificate, not against the sale.

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Case study 8

An Assignment Priced on an Equalisation Promise

A policy that leaves the assignee no better or worse off has to be computed, not just stated, and the hypothetical deduction runs alongside the real one. The engagement builds both and reconciles them at year end.

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All 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.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.
U.S. & Cross-Border Tax Returns
Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.
Expat & Emigration Tax
The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.
Non-Resident Canadian Tax
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.
Transfer Pricing & BEPS
Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.
Cross-Border Estates & Trusts
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Cross-Border Corporate Tax
Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.
India Tax for NRIs & Returning Residents
The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.
Canadian Tax with a Foreign Element
Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.
UAE Tax for Expats & Their Home Country
A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies
Global E-commerce & Marketplaces
  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces
Technology & SaaS
  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS
Importers, Exporters & Manufacturers
  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing
Athletes, Artists & Entertainers
  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers
Remote Workers & Digital Nomads

Working from anywhere doesn't mean taxed nowhere: residency defaults, employer payroll exposure and treaty relief decide where income actually lands.

Working from another country does not by itself end tax residence in the one you left, and it can start one where you are sitting. Day counts, ties, the employer's own exposure and the treaty tie-breaker all point at the same question, and the year you move is the year it has to be answered on paper.

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers
Investment Funds & Holding Companies
  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

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