Two things people confuse, with the rule for deciding which applies.
30 pages in this section. Two things people confuse, with the rule for deciding which applies.
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Every page in this section is written to the same standard: it opens with the block that exists nowhere else on the site — a threshold, a treaty article, a rule that applies to one group and not the one beside it — and it carries one worked example, worked through in full rather than a set of generalities.
Where a page needs a statutory threshold, a rate or a day-count, that figure is verified against the issuing authority before it ships. Where it cannot be verified for the year in question, the page states the mechanism and quotes no number, because a wrong threshold on a page like this is worse than no page at all. Every statutory page also carries the name of the person who reviewed it and the date they did.
Fees are fixed and agreed in writing before any work begins, and you review the finished work before it is filed. Documents move through a secure portal and you can meet us at any of our offices, so where you are makes no difference to how it works.
Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.
30 pages. Two things people confuse, with the rule for deciding which applies. Each one opens with the part that applies to that situation and nowhere else — a threshold, a treaty article, a filing that one group owes and the group beside it does not — and works one example through in full.
The fee is fixed and agreed in writing before any work begins, priced from the documents you send rather than estimated afterwards, and it does not move once accepted. You see the finished work and approve it before anything is filed.
A named adviser reviews every return and every information filing before it goes out, and the statutory pages on this site carry the name of the person who reviewed them and the date they did it. You approve the finished work yourself as the last step.
Send what you have — a return, a notice, a set of statements, in whatever state it is in — through the secure portal after the first call, and you get a written fixed fee back. Or call the 24-hour helpline on +1 (416) 619-0068 and we will tell you what is needed.
Usually because the two things share a name, a form, or a general category but are governed by different rules underneath — the comparison page exists specifically because the surface similarity is misleading, and states the actual test for telling them apart.
It gives you the rule for deciding which of the two applies, but confirming it against your own specific facts — particularly where they sit close to the dividing line — is still worth a direct review rather than relying on the general rule alone.
Nothing is priced from a phone call. We read what you have first, then the fee is set — so the scope and the number are agreed on the same evidence.
The practitioner who prepared and reviewed your file is the one who answers the question about it.
Quoted from your documents and agreed in writing. The number you accept is the number you pay.
Which return goes first decides whether relief can be claimed at all. That sequence is worked out before anything is submitted.
Quoted up front, in writing.
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Each of these carries its own guide, pricing pointers and FAQ.
A company engaged a worker abroad on a contractor agreement and paid gross for well over a year. The host country applied its own test to the substance of the relationship and reached the opposite conclusion. The work was to compare the classification tests on both sides, document the features of the engagement that actually drove the result, and register the employer where registration should have been running. The engagement produced a corrected classification, the host-country payroll filings brought into existence, and an agreement rewritten to match what the parties were really doing.
The client met the domestic residence test in both countries in the same year, and each authority's guidance, read on its own, said they were resident there. The work was to apply the treaty's tie-breaker in sequence rather than argue about the domestic tests, gathering the evidence each stage of it turns on. It did not end there, which was the important part: the country that lost the tie-break still had filings of its own. The engagement produced a documented tie-breaker position and returns in both countries that reflect it consistently.
The client had been relieving foreign tax against domestic tax for years without asking whether the source country was entitled to charge what it had charged. On part of the income it was not. The work was to establish the treaty position first, reclaim from the source country where its charge exceeded what the treaty permits, and restate the credit claimed at home to match. The engagement produced a corrected position in both countries and an order of operations the client now applies each year.
The client had filed a full-year return on one side and nothing on the other, because the alternative looked complicated. The year in fact split at the date residency changed, with departure consequences attaching at that point and only certain income reachable afterwards. The work was to fix the date of the split on evidence, allocate each income stream to the period it belonged to, and prepare the two filings so they agreed. The engagement produced a filed pair of returns for the year, and the departure position documented alongside them.
The client wanted the missed years gone by the weekend and was ready to file them as they stood. The work was to make the choice deliberately first: what the exposure actually was, whether the history could be explained plainly, and what protection each route offers. On these facts the disclosure route was the right one, and filing first would have closed it. The engagement produced a submission prepared as a whole, with the account of how the omission arose drafted to match the documents rather than the other way round.
The family assumed that because the deceased had never lived in the other country, that country had no claim on the estate. Certain assets are reached by where they are situated rather than by where their owner lived, and some of the holdings were. The work was to identify which assets the situs rules reach, then test what relief the treaty gives against the resulting charge. The engagement produced a schedule of assets classified by the basis of charge, the filings in each country prepared from it, and the relief claimed with its evidence attached.
A dwelling left available is the tie the CRA weighs most heavily, and its treatment differs depending on whether it is rented at arm's length. The file settles the residence position first and the rental reporting second.
Read how this one runsA reduced rate under a treaty is available only where the payer is satisfied the recipient is resident in the treaty country. The certificate and the withholding form are what make the rate available at source instead of recoverable a year later.
Read how this one runsAll case studies — every published engagement in one place.
Strategy and compliance for income, assets and families spread across borders.
Performance income is taxed where earned — Regulation 105 in Canada, withholding agreements in the U.S. — with special treaty articles overriding the usual rules.
Performance income is taxed where the performance happens, and the deduction is usually taken at source on the gross fee before expenses. Recovering the difference is a filing exercise in the other country, and it only works if the tour, the residency and the withholding certificates were documented while the work was being done.
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