Tax withheld at source is often the first and only tax a non-resident meets. These guides explain the certificates that reduce or remove withholding, the forms a payer will ask for, how over-withheld amounts are recovered, and why a refund claim has a deadline of its own.
Withholding & Forms — 1 in-depth guide
What Is US Withholding Tax on Dividends
What is us withholding tax on dividends — 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, Working Across Borders, Canada–US Corridor, Residency & Status, NRI & India.
What these engagements turn on
Non-resident services fee's withholding waiver applied for before payment
A payer making a fee payment to a non-resident for services performed in Canada needed a withholding waiver applied for before the invoice was paid rather than recovering the amount afterward through a return. We prepared and filed the waiver application ahead of the invoice date so the reduced withholding applied at payment.
Non-resident seller's clearance certificate obtained before the holdback was released
A non-resident seller of Canadian real estate needed a clearance certificate obtained on the correct basis before the purchaser's holdback could be released at closing. We prepared the certificate application on the correct valuation basis and obtained it ahead of the closing date.
Non-resident payee's treaty entitlement established before reduced withholding applied
A company paying dividends and interest to a non-resident needed the recipient's treaty entitlement established before the reduced withholding rate could actually be applied to the payments. We confirmed the recipient's entitlement under the applicable treaty and set the correct reduced rate before the payments were made.
A Certificate Obtained Before the Money Moved
An application for a reduced or nil deduction is made in advance and decided on the computed liability, not on the gross amount. Applying after the payment leaves a refund claim in place of a certificate.
Read how this one runsCanadian Dividends and Interest Paid to a Non-Resident
Flat withholding applies at source whether or not a return would produce the same figure. The engagement establishes treaty entitlement, files what is needed to claim the reduced rate, and recovers what went out at the domestic rate.
Read how this one runsA 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.
Read how this one runsA 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.
Read how this one runsA Canadian Landlord With Property in the United States
Gross withholding on US rents takes no account of mortgage interest, tax or repairs, so a leveraged property can face tax on turnover. An election onto net basis fixes that, and it has its own timing and its own filing.
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
Software revenue crosses borders by default — sourcing rules, withholding on licence-like payments and IP location decide the effective rate.
Software revenue is rarely taxed where the team sits. Licence, subscription and service income are characterised differently by each side, and the answer decides withholding at source, treaty relief and whether a foreign customer creates a taxable presence at all — questions that are cheap to settle before the contract and expensive afterwards.
- 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
- 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
