Case study 1
Withholding on a consultant invoice reduced by a waiver
A non-resident consultant had a contract to deliver work at a Canadian client site and would have had tax taken from the gross fee, despite subcontractor costs and travel absorbing much of it. We prepared the waiver application on the income and expense basis, assembled the supporting contracts and cost estimates, and lodged it in time for the payer to act on before the first invoice fell due. The engagement produced an approved waiver, a payment released on the reduced basis, and a filing record that supported the position when the Canadian return was later prepared.
Case study 2
An assignment to Canada planned before the employees travelled
An employer was sending staff to a Canadian site for a project and had assumed that because the workers remained on a foreign payroll, nothing Canadian arose. Employment income for Canadian workdays is exactly what the payroll route captures. We reviewed the treaty position for each employee and the employer's own standing, applied for the relief that was open at the start of the assignment, and set up the tracking of Canadian workdays. The engagement produced authorised relief before the first payroll run and a day-by-day record supporting it.
Case study 3
A contractor who was really an employee all along
A company had engaged a non-resident on a contract for services, treated the payments as fees, and withheld on that footing. The working relationship, on examination, had every feature of employment: set hours, supervision, tools provided and no other clients. We set out the analysis, quantified what the payroll route would have required for the Canadian workdays, and approached the authority with the position rather than waiting to be asked. The engagement produced a corrected classification, the payroll obligations brought up to date, and a documented basis on which the relationship continued.
Case study 4
Gross fee withholding recovered through a non-resident return
A non-resident supplier learned about the withholding requirement only when the first payment arrived short, by which point a waiver could do nothing. We collected the withholding documentation from each Canadian payer, prepared the accounts of the Canadian engagement so that the costs of earning the fees could be deducted, and filed the non-resident return. The engagement produced a filed return claiming credit for every amount withheld, a refund of the excess over the tax actually due, and a waiver plan for the following contract so the same money did not sit with the authority again.
Case study 5
A treaty exemption documented before the first payment fell due
A non-resident company with a short Canadian engagement had a clear treaty position but no way to stop its Canadian customer withholding. We prepared the waiver application on the treaty basis, with the certificate of residence and the contract terms that established why the relief applied, and dealt with the queries that came back. The engagement produced an approved waiver in the payer's hands ahead of the payment date, and a written file explaining the basis, which the customer kept for its own records of why it had paid gross.
Case study 6
A payer left holding the liability after paying gross
A Canadian company had paid a non-resident supplier in full without withholding, on the supplier's assurance that no Canadian tax arose. The obligation, and the exposure, sat with the payer. We reviewed the contracts and the work actually performed in Canada, established the amounts that should have been withheld, and set out the options for regularising them. The engagement produced a quantified position, an approach to the authority made by the company rather than prompted by an audit, and a procedure for checking non-resident payments before they were released.
Case study 7
Which Country Taxes the Salary
The employment article turns on where the work is done, who pays, and who bears the cost — three tests that can point in different directions. The file establishes all three before either return is drafted.
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Case study 8
A Home Kept in Canada After the Move Abroad
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.
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