Arrival valuation — meaning in cross-border tax

Arrival valuation explained: its meaning in cross-border practice, and why it matters to your filing.

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Definition

Documentation of what property was worth on the day residence began, which sets the cost base and cannot be recreated years later.

Why it matters

These concepts are all anchored to a transition. Almost everything available before it becomes taxable after it, and the date is usually within the client's control.

The team reviewing a file together at a desk

Where cross-border trouble starts

A definition that is settled at home may be contested in the other country, or may exist there under a different name with different consequences. That is why we identify the governing system before applying the term rather than after.

Where it appears in a filing

Arrival valuation comes up in the pages below, which is usually a faster route than the definition itself — the term is only useful once you can see which filing it changes.

What to do next

Recognising Arrival valuation in your own paperwork is the useful skill. Working out which side of it you fall on is a short call. Describe the situation in your own words; translating it into forms is our job.

If there is a single lesson from files that went wrong on a term like this, it is that the concept was understood and the evidence was not assembled. The definition is the easy half.

Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

International tax accountant — what this page covers

Read this page for international tax accountant. It works through arrival valuation from the beginning — whether it applies to you at all, what has to be filed if it does, and what the engagement costs, priced up front.

Files that look like this one

Case study 1

Fixing the arrival cost base for a portfolio in the year of arrival

A client arrived holding listed investments, two foreign properties and an interest in a private trading company. We separated the holdings that could be evidenced from published data, where a dated schedule of positions was sufficient, from those needing a report, and commissioned valuations for the property and the shareholding while the date was recent. Instructions, reports and the currency sources used were filed together. The engagement produced a documented cost base for every asset held on the day residence began, ready for whenever a disposal happens.

Case study 2

A sale years after arrival with no evidence of the starting value

A client sold a foreign property some years after moving and had no record of its value on arrival. We assembled comparable transactions from the arrival period, the purchase history, dated photographs and the condition evidence that survived, and instructed a retrospective valuation setting out what could and could not be established. The return disclosed the basis on which the figure had been arrived at rather than presenting it as observed. The work produced a supportable starting value with its assumptions stated, and a written record of why a contemporaneous figure was unavailable.

Case study 3

Valuing a founder's shareholding against the instructions that commissioned it

A founder arrived while holding a minority stake in an unquoted company with no recent transactions in its shares. We drafted the instruction letter first, settling the basis of value, the valuation date and the information the valuer would be given, then had the report prepared against it. The bridge from the company's last accounting date to the arrival date was documented in the report. The engagement produced a valuation, the instructions behind it, and a note of the assumptions a reviewer is most likely to test.

Case study 4

Apportioning jointly held foreign property between two arriving spouses

A couple arrived owning property abroad in undocumented shares, with the legal title in one name and the funding provided by both. We established what each person's interest actually was from the funding trail and the local title documents, valued the property as at the arrival date, and recorded the apportionment each spouse would rely on. Both returns now refer to the same valuation and the same split. The work produced one valuation, two documented interests, and a file explaining how the division was arrived at.

Case study 5

Separating an inherited value from the value on arrival

A client had inherited assets abroad before moving and assumed the probate figures would serve as the starting cost base. The two dates were years apart and the probate valuation had been prepared for a different purpose and on a different basis. We valued the assets as at the day residence began, kept the probate papers in the file as history rather than as the cost base, and documented why the two figures differ. The engagement produced the correct arrival figure and a note preventing the earlier one being used by mistake.

Case study 6

Matching the arrival record to what the departure country had already fixed

A client left one country in the same year as arriving in another, and the country of departure had fixed values on the day residence ended. We obtained those figures and the reports behind them, prepared the arrival documentation for the same assets, and set the two side by side so any difference in date, basis or currency treatment was visible and explained. The engagement produced a single schedule showing each asset's value under both records, which the client keeps with the filings for both countries.

Case study 7

First Canadian Return After Arriving Mid-Year

The arrival date splits the year and sets the cost base of what you brought with you. Getting that date and those values right is what determines whether a later sale is taxed on the whole gain or only on the part that accrued after landing.

Read how this one runs
Case study 8

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 runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

Cross-border tax for sellers shipping worldwide: marketplace withholding, foreign registrations and inventory nexus handled before they become audits.

Marketplaces withhold, remit and report in their own right, so the tax position of a single sale is decided by where the stock sat, where the buyer was and which platform collected — not by where the company is registered. We reconcile the platform's own filings against the returns before either is submitted.

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Arrival valuation: further questions

What is my cost base for property I owned before I moved here?

In systems that tax gains from the date residence begins, the cost base for that purpose is generally the value of the asset on the day you arrived, not the price you originally paid. The gain that accrued while you were elsewhere sits outside the new country's charge, and the arrival value is the line between the two. That makes the arrival figure a number you will need on a return years or decades later, when the asset is sold. It is also a number that has to be evidenced as at a date that will by then be long past.

Which assets need a valuation on the day I arrive?

Anything whose value on that day cannot be looked up afterwards. Listed shares, funds and currency balances can be reconstructed from published data, so a note of the holdings and the date is usually enough. Private company shares, partnership interests, real property, land, unquoted debt, intellectual property, artwork and jewellery cannot, and those are the ones to value while the date is current. Apply the same test to anything held jointly or through a structure, because the asset to be valued is your interest in it rather than the whole. Start from the list of what you own, not from what feels valuable.

Can I get a valuation years after I moved?

A retrospective valuation can be prepared, and for some assets it is defensible. Real property has comparable transactions that survive. Private company shares are harder, because the accounts of the period tell you what the business reported and not what a buyer would have paid, and the information a valuer would have relied on at the time may no longer exist. The further back the date, the more the report rests on assumption rather than evidence, and the more of it a reviewer can question. A valuation prepared close to the arrival date is a document; one prepared much later is an argument.

Who can value shares in my own private company at the arrival date?

Someone independent, working to a stated basis of value, with the instructions and the date recorded in writing. The report should say what was valued, at which date, on what basis, what information was relied on and what was assumed. Keep the instruction letter with the report: without it, nobody later can tell whether the valuer was asked the right question. Where the company's own accounts are the main input, note the period they cover and how the valuer bridged from the accounting date to the arrival date. The reasoning is what makes the figure usable, not the figure itself.

How do I fix the value of a foreign asset in local currency?

Two steps, both dated. First value the asset in the currency it is denominated in, as at the day residence began. Then convert at a rate for that date, and record which published source the rate came from. Keeping the two steps separate matters, because a reviewer may accept the asset value and question the conversion, or the reverse, and a single blended figure cannot be unpicked. Where the asset and your reporting currency are different again, note the chain. The exchange source and date belong in the file next to the valuation, not in somebody's memory.

Do I need an arrival valuation if I am not planning to sell?

The valuation is not for the sale, it is for the date. Its whole purpose is to record something that can only be observed once, on the day residence began, and intention has no bearing on whether that day passes. Plans change, assets are sold on divorce, death, emigration or an unexpected offer, and structures are reorganised for reasons that have nothing to do with tax. When any of that happens, the arrival value will be asked for and will no longer be observable. Documenting it is a small cost paid once against a figure you cannot recreate.

What happens if the two countries disagree about which of them can tax me?

The treaty has a procedure for exactly that. You apply to the competent authority in your residence country, which takes the case up with its counterpart, and the two negotiate a position that removes the double taxation. Some treaties add binding arbitration if they cannot agree. It is slow and it runs on documents, so the practical work is preserving the record and filing protective claims while the clock runs. See our treaty work.

How much foreign income is tax-free in Canada?

None of it is tax-free for being foreign. A Canadian resident is taxed on worldwide income, so foreign salary, interest, dividends, rent and gains all go on the return, converted to Canadian dollars. What genuinely reduces the bill is the basic personal amount, the credit for foreign tax already paid, and any treaty article that exempts a specific type of income. The reporting thresholds people have in mind — the foreign property statement, for one — govern reporting, not exemption. See the foreign tax credit.

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Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

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