Cross-border tax terms — D

17 terms beginning with D, each defined at mechanism level.

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The definitions here are unnumbered on purpose. A concept survives a budget; a threshold does not, and the two are easy to confuse once they sit in the same sentence.

Most of these terms exist because two tax systems describe the same thing differently, or because one system has a concept the other does not. That is where cross-border files go wrong quietly: a position that is obviously right at home has no counterpart abroad, and the mismatch — rather than the rate — becomes the exposure. So every entry is written in three parts: the meaning, the point at which it costs something, and the filings on this site that it governs.

If a term like this is in a notice you have received, bring the notice. The definition matters far less than what the sender is actually asking for. Every page here carries the name of the person who reviewed it and the date they did.

  • Deemed resident — Someone treated as resident by a statutory rule rather than by ties.
  • Dual-status alien — Someone who is a non-resident for part of a US tax year and a resident for the rest, usually in the year of arrival or departure.
  • Domicile — A concept of permanent home used by several systems alongside residence.
  • Deemed disposition — A rule that treats property as sold at market value even though nothing was sold — on emigration, on death, or on a change of use.
  • Departure tax — The tax on the deemed disposition triggered when residency ends.
  • Double taxation — The same income taxed twice.
  • DTAA — Double taxation avoidance agreement — the term used in India for a tax treaty.
  • Dual consolidated loss — A loss usable in two countries by the same economic group, restricted by rules designed to prevent it being deducted twice.
  • DEMPE — Development, enhancement, maintenance, protection and exploitation — the functions that determine which entity is entitled to an intangible's return, regardless of legal ownership.
  • Dependent agent — A person who habitually concludes contracts, or plays the principal role leading to them, on behalf of a foreign enterprise — creating a taxable presence without premises.
  • Deemed dividend — An amount treated as a distribution although not declared as one — commonly a shareholder benefit, a loan or a secondary transfer-pricing adjustment.
  • Deemed disposition on death — The rule treating most capital property as sold at market value immediately before death, which is how Canada taxes at death instead of levying an estate tax.
  • Delinquent FBAR — A late account report filed with a reasonable-cause statement where the income was reported and no examination is under way.
  • Distance selling — Cross-border sales to consumers, which trigger registration in the destination country once its own test is crossed.
  • Day-count record — A contemporaneous record of presence by country.
  • Departure valuation — Documentation of value on the day residence ended, which fixes the deemed disposition and is the figure most likely to be challenged.
  • Dual citizenship — Holding two nationalities.

What the D entries have in common

17 terms begin with D. Follow the entry itself for the mechanism, the filings it decides, and the fixed fee attached to that work. Three to start with: Deemed resident, Dual-status alien and Domicile.

Nearby letters

C — 25 terms · E — 19 terms. The full A–Z lists all 297 terms in one place.

Back to the full glossary · Cross-border tax answers · Side-by-side comparisons

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Files that look like this one

Case study 1

Split year allocated by when the income was earned

A bonus and a share award both paid after arrival related to work performed before the move, and the whole amount had been reported in the resident part of the year. We traced each item to the period it was earned over, allocated it between the two parts of the year on that basis, and documented the reasoning with the grant and vesting records. The engagement produced a corrected split-year filing and a written allocation method the client can apply to later awards.

Case study 2

Departure assets valued on the day the ties ended

A client leaving the country held a portfolio, private company shares and a property, and had assumed the deemed sale rule applied to none of it because nothing was being sold. We identified which holdings the rule reached and which were outside it, obtained valuations as at the cessation date rather than an approximate one, and set the figures out for the departure return. The work produced a valued asset schedule with supporting evidence attached to each entry.

Case study 3

Deemed residence category identified for a posted family

A family posted abroad had filed as non-residents on the basis that their ties had gone, without considering that residence can arise by rule rather than by ties. Reviewing the terms of the posting showed which statutory category applied to the employee and how it reached accompanying family members. The engagement produced filings on the correct footing for each member of the household, and a written note of how the other country's treatment interacts with it for the remainder of the posting.

Case study 4

Deferral arranged so a departure charge was not paid early

The deemed sale on departure produced a liability on assets the client had no intention of selling and no cash to pay tax on. We set out which assets drove the charge, what security would be acceptable to defer payment until an actual disposal, and what the deferral costs and requires over time. The work produced a departure filing with the deferral in place, so the tax follows the eventual sale rather than falling due against illiquid holdings.

Case study 5

Arrival year filed as two parts after a mid-year move

An individual who moved during the year had filed the whole year on a single basis, which overstated the income exposed in the pre-arrival part and claimed reliefs restricted in a split year. We established the residence start date from the facts, divided the year at it, and prepared each part on the basis applying to it. The engagement produced an amended split-year filing and a schedule showing how each income item was assigned and why.

Case study 6

Departure file assembled while the evidence still existed

A client leaving the country was asked to gather the ordinary records of a move before anything was filed: the lease termination, the sale documents, removal invoices, account closing statements, the end of health cover and the first registration abroad. None of it was difficult to obtain at the time and most of it becomes hard within a year. The engagement produced a dated evidence file behind the cessation date, which is what a later reassessment asks to see.

Case study 7

Treaty Rate Refused Because the Paperwork Was Missing

A 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.

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Case study 8

Canadian Dividends and Interest Paid to a Non-Resident

Flat withholding applies at source whether or not a return would produce the same figure. The engagement establishes treaty entitlement, files what is needed to claim the reduced rate, and recovers what went out at the domestic rate.

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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.
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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.
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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.

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