Cross-border tax terms — R

16 terms beginning with R, 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.

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. Each page below follows the same shape — definition, consequence, and the specific returns or elections the term reaches.

If this term has turned up in a letter, a slip or an adviser's email and you are not sure which side of it you are on, that is a short call to the helpline rather than a research project. Every page here carries the name of the person who reviewed it and the date they did.

  • Resident alien — A non-citizen taxed by the United States as a resident, on worldwide income, because they hold a green card or meet the substantial presence test.
  • RNOR — Resident but not ordinarily resident — India's transitional category.
  • Regulation 105 — The Canadian withholding on fees paid to a non-resident for services rendered in Canada, computed on gross fees and reducible in advance by a waiver.
  • Regulation 102 — The Canadian payroll withholding on employment income earned in Canada by a non-resident employee, waivable where a treaty exemption applies.
  • Resale price method — A method testing the gross margin earned by a reseller, sensitive to consistent classification between cost of sales and operating expense.
  • Reverse hybrid — An entity treated as a company by the country of establishment and as transparent by the investor's country, the mirror image of the classic hybrid.
  • Repatriation — Getting profits home.
  • Resident contributor — A person resident in the country who transferred or loaned property to a foreign trust — which is enough to make the trust deemed resident under some rules.
  • Reasonable cause — The standard for penalty relief based on circumstances an ordinarily prudent person could not have avoided, evidenced with dates and documents.
  • Reassessment period — The window during which a tax authority may reassess a year.
  • Reassessment notice — A notice reopening a closed year.
  • Reverse charge — A mechanism shifting the obligation to account for tax from the foreign supplier to the local business customer.
  • Restricted share unit — An equity award generally taxed at vest, which means an employee who moved between grant and vest owes tax in a country they have left.
  • Repatriable funds — Money that may lawfully be sent out of India, determined by the account it sits in and how it got there — a separate question from whether tax is owed.
  • Reviewer sign-off — The named review of a statutory filing before it goes out, with the reviewer and the date recorded on the advice.
  • Rollback — The extension of an advance pricing agreement to earlier years on the same transactions, available in some countries including India.

What the R entries have in common

16 terms begin with R. 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: Resident alien, RNOR and Regulation 105.

Nearby letters

Q — 3 terms · S — 39 terms. The full A–Z lists all 297 terms in one place.

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What these engagements turn on

Case study 1

Residency Changed Mid-Year and Both Returns Assumed a Full One

A move part-way through a year produces two part-year positions, not two full ones. The engagement establishes the date residence actually changed, allocates income either side of it, and amends whichever return was filed on the wrong footing.

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Case study 2

Paying a Dividend Up to a Foreign Parent

The withholding rate depends on the treaty, on the size of the holding, and on whether the parent is the beneficial owner rather than a conduit. Establishing all three before the payment is what secures the lower rate at source.

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Case study 3

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 4

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.

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Case study 5

Canadian 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.

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Case study 6

Three Countries in One File and Two Treaties That Disagree

Income sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.

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Case study 7

US Estate Tax on Assets a Canadian Did Not Know Were Exposed

US shares and US real estate sit inside the US estate tax net regardless of where the owner lives. The treaty provides relief that is proportionate rather than automatic, and the calculation depends on the worldwide estate.

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Case study 8

Putting a Foreign Hire on a Canadian Payroll

The obligation sits on the payer, and the payer is liable for what it failed to withhold. Registration, the residence question and any treaty exemption are settled before the first pay run rather than after.

Read how this one runs

All 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.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

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.

Canadian Tax with a Foreign Element

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.

UAE Tax for Expats & Their Home Country

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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Global E-commerce & Marketplaces

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Technology & SaaS

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Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
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Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
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Remote Workers & Digital Nomads

Working from anywhere doesn't mean taxed nowhere: residency defaults, employer payroll exposure and treaty relief decide where income actually lands.

Working from another country does not by itself end tax residence in the one you left, and it can start one where you are sitting. Day counts, ties, the employer's own exposure and the treaty tie-breaker all point at the same question, and the year you move is the year it has to be answered on paper.

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
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Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
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