Cross-border tax terms — G
10 terms beginning with G, each defined at mechanism level.
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Each entry answers two questions — what the term picks out, and what changes once it applies. Neither answer needs a number, and a number in a definition tends to outlive its accuracy.
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. Each page below follows the same shape — definition, consequence, and the specific returns or elections the term reaches.
Where a term like this affects your own position, the answer depends on dates and documents rather than on the definition — which is why we start with those. Every page here carries the name of the person who reviewed it and the date they did.
- Green card test — The rule that makes a lawful permanent resident a US tax resident for as long as the status is valid, whether or not they live in the United States.
- Grossing up — Restating a net-of-tax amount to its pre-tax equivalent, needed whenever a foreign payment arrived after withholding and the credit is claimed on the gross figure.
- GILTI — Global intangible low-taxed income — a current US inclusion of a controlled foreign corporation's active earnings above a routine return on tangible assets.
- GloBE rules — The model rules implementing the global minimum tax, including the income inclusion and undertaxed payments mechanisms.
- GAAR — A general anti-avoidance rule allowing an authority to recharacterise an arrangement whose main purpose was a tax benefit, even where each step complied with the law.
- Graduated rate estate — An estate that qualifies for graduated rates for a limited period after death, subject to conditions met from the first return onwards.
- Gift splitting — The election treating a gift by one spouse as made half by each, which changes the exemption and reporting position.
- Grantor trust — A trust whose income is taxed to the settlor rather than to the trust or beneficiaries, because of powers or interests the settlor retained.
- GST/HST — Canada's federal and harmonised sales taxes.
- GIFT City — India's international financial services centre, operating on a different tax and regulatory basis from the rest of the country.
What the G entries have in common
10 terms begin with G. What the entry under this letter turns on is set out on its own page, together with the returns it reaches and what we charge to handle them. Three to start with: Green card test, Grossing up and GILTI.
Nearby letters
F — 39 terms · H — 4 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
Bringing a long-absent green card holder back into compliance
The client had returned to their home country many years earlier, had filed nothing in the United States since, and assumed the card was spent once it expired on its face. We established that the status had never formally ended, identified which years were in scope, and used the disclosure route appropriate to a taxpayer whose failure was not wilful. The engagement produced the income returns and information reports for the years covered, a written explanation of the circumstances filed alongside them, and a decision taken on advice rather than by drift about whether to keep the status at all.
A gross-up recalculated for an assignee under tax equalisation
The employer had promised a net salary and had been applying one flat uplift across everyone on the policy, in both countries, across successive assignment cycles. The figure was right for nobody. We rebuilt the calculation for the individual, taking account of the fact that tax met on their behalf is itself remuneration in each system, and reconciled it to the year-end reporting. The engagement produced a corrected calculation, amended year-end slips, and a method the payroll team now applies per assignee and per country instead of one uplift for the whole population.
Estate exposure reviewed for a green card holder living abroad
The client had left the United States but kept permanent residence, and had been given contradictory advice about whether their worldwide estate sat within the US net. Two questions had been run together: residence for income tax and the connection that matters on death are decided by different tests. We separated them, set out how each country would see the assets, and reviewed the wills alongside the tax position rather than after it. The engagement produced a written analysis for the family and their lawyer, and a short list of steps available while the client was alive that would not be afterwards.
A treaty tie-break documented rather than quietly assumed
The client, resident in their home country but holding a green card, had been taking a treaty position informally for years on the basis that tax was paid where they lived. Nothing was disclosed and nothing was written down. We tested the tie-break properly against the facts, considered what relying on it would mean for someone who had held the status a long time, and made the position explicit. The engagement produced returns with the treaty position disclosed on their face, the information reporting that runs regardless of the tie-break, and a record of the reasoning for the years ahead.
A relocation payment grossed up on the wrong base
A one-off payment to a new arrival had been grossed up using the calculation the employer applied to ordinary salary, which ignored both the different treatment that payment received and the second country's view of it. The error reached the employee's year-end reporting and their own return. We recomputed the payment, established what each country would tax and when, and coordinated the correction between payroll and the individual so the two filings agreed. The engagement produced amended employer reporting, a return the employee could file consistently with it, and a rule for how one-off payments are handled next time.
Establishing the year a surrendered green card stopped mattering
The client needed to know, for a bank and for their own filings, the year in which their US residence ended. The card had been handed in at a border crossing with no copy kept, and the family's recollection of the date varied. The work was evidentiary rather than technical — travel records, correspondence, the institution's own files — to fix a defensible date and then file consistently with it on both sides. The engagement produced a documented end date, returns for the years either side prepared on that basis, and a record the client can hand over when asked again.
Withheld at the Statutory Rate When a Treaty Rate Applied
Where withholding has already gone out at the full domestic rate, the treaty rate is recovered rather than applied. The file establishes entitlement for each payment, then puts the documentation in place so the following year runs at the correct rate from the start.
Read how this one runsOne Salesperson Abroad, and a Corporate Filing Obligation
A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to it.
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
Software revenue crosses borders by default — sourcing rules, withholding on licence-like payments and IP location decide the effective rate.
Software revenue is rarely taxed where the team sits. Licence, subscription and service income are characterised differently by each side, and the answer decides withholding at source, treaty relief and whether a foreign customer creates a taxable presence at all — questions that are cheap to settle before the contract and expensive afterwards.
- 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
- 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
