Employees and contractors who earn in one country while living in another face payroll withholding, day-count tests and social security questions that neither employer usually tracks. These guides explain how employment income is sourced and what a short assignment changes.
Working Across Borders — 1 in-depth guide
Do You Pay Taxes If You Work Overseas
A practitioner's guide to do you pay taxes if you work overseas: the rule that decides it, the claims that make it real, and the quick answers to every version of the question.
Other topics Foreign Income Basics, Business & Structure, US Expat Taxes, Retirement & Pensions, Withholding & Forms.
Files that look like this one
Inherited Indian property's cost base established at the point of inheritance
A person inheriting property in India while living abroad needed the correct cost base for a future sale established at the point of inheritance rather than at the time of the eventual disposal. We established the basis at inheritance and documented it for use whenever the eventual sale actually occurred.
Indian shares held from abroad characterized by holding period before filing
An individual holding Indian shares from abroad needed the character of the resulting gain determined by holding period before the return covering the disposition was prepared. We reviewed the holding period against the applicable rule and characterized the gain correctly before the return was filed.
Isolated missed account disclosure corrected under the narrow late-filing route
A taxpayer who had reported the underlying income but missed a related foreign account disclosure needed the narrow late-filing route assessed while the omission remained isolated to the account report alone. We confirmed the income had been reported, filed the missed disclosure under the available route, and closed out the gap.
The Deemed Sale That Happens on Death
Canada treats most capital property as sold at fair market value on death, so a terminal return can carry tax on gains nobody realised. Valuations and the order of the returns are what decide the figure.
Read how this one runsInheriting Property in India While Living Abroad
India does not tax the inheritance itself, but the later sale and the money leaving the country both have positions of their own. The file establishes the cost base to use on that sale and what the remittance will require.
Read how this one runsGains on Indian Shares Held From Abroad
Holding period and instrument decide the character of the gain, and the deduction at source applies before any of that is considered. The return is where the position is corrected.
Read how this one runsA 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 runsAccounts Reported Late When the Income Already Was
Where the income was on the return and only the account report was missed, a narrow route allows late filing with a reason attached. It is open only while no income is unreported and no examination has begun, which is why it is checked first.
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
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.
Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.
- 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
