Cross-border tax terms — 0-9
1 term beginning with a digit, each defined at mechanism level.
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What each entry gives you is the mechanism: the condition that triggers the term, and the consequence that follows. Amounts and rates belong on the filing pages, where they carry a tax year and a source.
Terminology is where cross-border risk hides. The rate is visible and gets checked; the classification is invisible and does not, which is why the classification is what usually goes wrong. Each page below follows the same shape — definition, consequence, and the specific returns or elections the term reaches.
Knowing the term is the first half. Knowing whether it applies to your year, and what evidence proves it, is the half that changes the outcome. Every page here carries the name of the person who reviewed it and the date they did.
- 183-day rule — The common shorthand for a treaty employment article's presence test.
This letter holds one term, so this page is mostly a signpost to it. The A–Z above is the faster route if you arrived looking for something else.
183-day rule
The common shorthand for a treaty employment article's presence test. There is no single rule — each treaty measures its own period on its own basis. Follow the entry itself for the mechanism, the filings it decides, and the fixed fee attached to that work.
Nearby letters
Z — 1 term · A — 13 terms. The full A–Z lists all 297 terms in one place.
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Files that look like this one
Secondment planned around the wrong counting window
An assignment had been scheduled so that presence fell either side of a year end, on the assumption that the test ran on the tax year. The treaty article in question measured presence over a rolling window instead, so the two halves counted together. The work was to read the actual article, recount the days on the correct basis, and set out the position in writing before the return was prepared. The engagement produced a documented presence calculation and a filing consistent with it, rather than a claim that would have failed on the first enquiry.
Employment article conditions reviewed after a payroll recharge
A finance team had recharged the cost of a seconded employee to the host entity as a routine intercompany entry, without anyone connecting that entry to the treaty claim being made on the individual's return. Presence was well inside the limit; the condition about who bears the remuneration cost was not met. The work consisted of tracing the recharge, establishing which periods it covered, and restating the treaty position accordingly. The result was an amended filing and a written note to the payroll team about the entries that decide it.
Reconstructing a travel record from third-party sources
A taxpayer was asked to support a presence claim years after the fact and had only a spreadsheet prepared from memory. We rebuilt the record from border agency entry and exit data, airline records, card transactions and payroll location entries, and set out how each ambiguous day was treated and why. Some days moved against the taxpayer. The engagement produced a single reconciled travel record with its sources attached, which is the thing an enquiry actually asks for and the thing the original claim did not have.
Contractor treated as an employee by the host country
An individual invoicing through a personal company had relied on the employment article's presence test, which does not apply to an independent contractor at all. The host authority took the view that the relationship was employment in substance, given the supervision and the integration into local teams. Work consisted of reviewing the contract against how the engagement actually ran, identifying which article governed, and preparing the position on that basis. The outcome was a filed position under the correct article and a revised contracting arrangement for later periods.
Two authorities counting the same presence differently
The same set of travel dates had been accepted in one country and challenged in the other, because each applied its own treaty wording and its own approach to part days. Rather than argue the day count twice, we set out a single presence record and prepared parallel analyses showing how each authority's rules applied to it. The engagement produced a consistent evidenced position on both sides, and a written record of where the two treatments genuinely differ, which is the material any later relief claim depends on.
Assignment structure reviewed before the contract was signed
A company asked what would happen if a planned posting ran slightly longer than intended. The review covered the counting window in the relevant treaty, the employer of record, and whether the host entity would end up bearing the remuneration cost. Two of the three conditions were within the company's control and one was not. The work produced a written memorandum setting out the conditions, the evidence each one would need, and the point at which the planned arrangement would stop being supportable.
Green Card Kept, Moved to Canada — Both Returns Still Due
Holding a green card does not end the US filing obligation, and living in Canada starts a Canadian one. The engagement fixes residence under the treaty tie-breaker, then decides which return the relief is claimed on so the two do not contradict each other.
Read how this one runsTwo Passports, Two Returns, One Income
Dual citizenship does not let you choose which country taxes you. The work is establishing residence, applying the treaty article that governs each income type, and preparing both returns from one set of figures so they agree line for line.
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
- 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
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
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
