Cross-border tax terms — E
19 terms beginning with E, each defined at mechanism level.
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Every definition here is written at mechanism level: what the term means and what turns on it. No threshold, rate or day-count is quoted in a glossary entry, because a stale number in a definition is the one most likely to be copied into a filing.
These words matter because tax systems are not built to line up. One country recognises a structure the other cannot see, and the filing that is routine at home becomes a disclosure obligation abroad. Every entry closes with the filings it touches, because a definition you cannot attach to a form is not yet useful.
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.
- Emigrant — Someone who has ceased to be resident.
- Effectively connected income — US-source income connected with a US trade or business, taxed on a net basis at graduated rates on a return rather than by flat gross withholding.
- Economic double taxation — The same profit taxed in two hands — typically after a transfer-pricing adjustment in one country with no corresponding adjustment in the other.
- Exemption method — A relief method under which the residence country does not tax the foreign income at all, rather than taxing it and giving credit.
- Exchange of information — The treaty and multilateral machinery by which tax authorities share account and taxpayer data.
- Exempt surplus — A pool of a foreign affiliate's active business earnings from a treaty or agreement country, dividends from which can generally reach Canada without further Canadian tax.
- Excess distribution — A distribution from a foreign pooled investment above a permitted amount, thrown back across the holding period with an interest charge under the default regime.
- Exit charge — A payment for value transferred when functions, assets or risks are moved out of a jurisdiction in a restructuring.
- Earnings stripping — Rules limiting interest deductions by reference to earnings, operating alongside or instead of a debt-to-equity test.
- Economic substance — The requirement that an entity have real people, decisions and functions in its jurisdiction.
- Economic nexus — A sales-tax connection created by revenue or transaction volume into a state, without any physical presence.
- Effective tax rate — Tax as a proportion of a defined measure of profit.
- Estate tax treaty relief — Credits and marital mechanisms in an estate tax treaty that reduce a non-resident's exposure, pro-rated by the ratio of situs assets to the worldwide estate.
- Exempt supply — A supply outside the tax with no input tax recovery on its inputs, which is why the exempt-versus-zero-rated distinction is worth money.
- Equalisation levy — An Indian charge on specified digital transactions that sits outside the income tax act, so treaty relief and foreign credit arguments do not work on it in the usual way.
- Economic employer — The entity that in substance bears the cost and directs the work, which can differ from the legal employer and can defeat a treaty exemption.
- Engagement letter — The document setting the scope, the fee and the boundary with any other adviser.
- Evidence pack — The assembled documents supporting a residency, treaty or valuation position, built at the time rather than reconstructed under audit.
- Expat — Everyday shorthand for someone living outside their home country.
What the E entries have in common
19 terms begin with E. The term below is defined in full on its own page, alongside the filings it governs and the fee for dealing with them. Three to start with: Emigrant, Effectively connected income and Economic double taxation.
Nearby letters
D — 17 terms · F — 39 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
Files that look like this one
Social Security Contributions Owed in Two Countries at Once
A totalization agreement assigns contributions to one system and exempts the other, but only against a certificate obtained in advance. Without it both sets come out of the same salary and neither is straightforward to recover.
Read how this one runsPaid for Work Done in Canada While Living Elsewhere
Employment carried out in Canada is taxable here even where the employer and the bank account are not. The engagement establishes how many of the days were worked in Canada, applies the treaty employment article, and deals with the withholding the payer has already taken.
Read how this one runsFifteen Per Cent Held Back From a Fee for Services in Canada
A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.
Read how this one runsAn Adjustment in One Country and No Relief in the Other
A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.
Read how this one runsA Pension Taxed Where the Treaty Did Not Intend
Pension and annuity articles allocate taxing rights differently from employment income, and a flat withholding often exceeds what a return would produce. The alternative filing is elective and has a deadline.
Read how this one runsCanadian Pension Paid Abroad and Taxed at the Flat Rate
Pension and annuity payments to a non-resident carry a flat withholding that often exceeds what a return would produce. The alternative filing is elective, and whether it helps depends on the total income for the year rather than on the payment alone.
Read how this one runsA Secondment Whose Paperwork Decided the Tax
Who employs, who directs and who bears the cost are the facts a treaty article turns on, and an assignment letter is where they are recorded. Drafting it with the tax position in view prevents an argument later.
Read how this one runsAn IRS Notice for a Year the Client Believed Was Settled
Most notices are proposals rather than assessments, and they carry a response window that is shorter than it looks. The engagement reads what is actually being proposed, gathers the support, and replies inside the window with the position rather than a request for time.
Read how this one runsAll 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.
U.S. & Cross-Border Tax Returns
Expat & Emigration Tax
Non-Resident Canadian Tax
Transfer Pricing & BEPS
Tax Treaties & Withholding
Cross-Border Estates & Trusts
Global Investments & Reporting
Cross-Border Corporate Tax
India Tax for NRIs & Returning Residents
Canadian Tax with a Foreign Element
UAE Tax for Expats & Their Home Country
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Professional Services Firms
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance



