Case study 1
Fixing a departure date the facts did not support
The client had used the date of their flight as the day they ceased to be resident, while a home and family remained in Canada for some months afterwards. The return had been prepared on that footing. We reviewed the ties one by one, established the date the record actually supported, and reworked the year around it. The engagement produced a revised departure-year return, a written statement of the date and the reasoning behind it, and the supporting material held with the file.
Case study 2
An inventory built before anything was computed
The client was leaving within the year and wanted to know the exposure. Rather than start from the assets they happened to mention, we built a full inventory of property held as at the planned departure date, placed each item inside or outside the deemed disposition with the reason recorded, and identified the values that would need support. The engagement produced a departure-year plan, a list of valuations to obtain while still in the country, and the order in which the steps should happen.
Case study 3
A deemed disposition discovered two years after leaving
The client had emigrated, filed the departure year as an ordinary return, and heard nothing until a later transaction raised the question. The deemed disposition had never been reported. We reconstructed the holdings and the values as at the departure date from the records available, prepared the reporting that should have accompanied that year, and set out the position on the later transaction in light of it. The engagement produced a corrected departure year and a documented basis for the disposal that followed.
Case study 4
Canadian rental income that kept the filing alive
The client assumed emigrating ended their Canadian filing. A property left behind continued to produce rent, with amounts withheld by the payer in the meantime. We established the departure date, separated the resident and non-resident parts of the year, and set out the obligations attached to the rental income and how the withheld amounts would be reconciled. The engagement produced the departure-year return, the first non-resident filing, and a schedule for the years the property continues to be held.
Case study 5
A work permit holder leaving with ties on both sides
The client had come to Canada on a work permit, kept connections in their home country throughout, and was now leaving. Whether they had ever been resident, and if so from when until when, had never been documented. We worked the question from the record of ties and presence, fixed the start and end of the resident period, and prepared the years on that basis. The engagement produced a documented residence period, the departure-year filing, and a note of what the other country's system would be told.
Case study 6
Planning a departure around a later return to Canada
The client expected to leave and come back within a few years, and wanted the departure handled so that the eventual return would not be a second untangling. We set out what the departure year would involve on the facts as planned, which choices were available and when they would have to be made, and what records to keep while away. Nothing was filed at that point. The engagement produced a written plan, a document list, and the points to revisit once the departure date was fixed.
Case study 7
Withholding Reduced by the Right Article
Dividends, interest and royalties each have their own article and their own rate, and the payer applies whichever it is satisfied of. Establishing entitlement before payment is what secures the lower rate at source.
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Case study 8
Paid 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.
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