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.
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Files that look like this one
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 runsA Retirement Plan That Grows Tax-Deferred in Only One Country
Cross-border retirement accounts are recognised by treaty, but the deferral usually has to be elected rather than assumed. The engagement checks whether the election was made, makes it where it was missed, and reports the account on whichever side requires it.
Read how this one runsWithholding 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.
Read how this one runsA Taxable Presence Created Without an Office
A dependent agent habitually concluding contracts can create a permanent establishment where there is no premises at all. The review tests what the person actually does against what the treaty describes.
Read how this one runsA Relief That Turned on Days Nobody Had Recorded
Treaty exemption, residence and social security are each decided by a count that has to be evidenced rather than recalled. The engagement builds the record from tickets, rosters and payroll before applying any article.
Read how this one runsWhich Country Taxes the Salary
The employment article turns on where the work is done, who pays, and who bears the cost — three tests that can point in different directions. The file establishes all three before either return is drafted.
Read how this one runsAn Estate That Cannot Distribute Until the Clearance Comes
An executor who distributes before the clearance certificate can be held personally liable for what is later assessed. The file prepares the final return and the estate return, and applies for the clearance in the order that lets the estate close.
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
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Cross-Border Estates & Trusts
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Industries & Client Types We Serve Worldwide
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Technology & SaaS
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
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Professional Services Firms
- Reg 105 / 102 waivers
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- Section 216 rental returns
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Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
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Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
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Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
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Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
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