Case study 1
A waiver obtained part-way through a Canadian engagement
A consultant based abroad had invoiced the first stage of a Canadian project and found the deduction taken on the whole invoice, including the travel and the subcontractor charges inside it. The work was to apply for relief covering the remaining stages, setting out the contract, the days to be worked in Canada, the treaty basis and the expected Canadian tax against the amount being withheld, and separately to file for the amount already deducted. It produced authorised relief for the rest of the engagement and a return that recovered the first deduction.
Case study 2
A Canadian payer who had never deducted on foreign invoices
A Canadian business discovered during a review that it had paid a series of foreign specialists for work performed at its own premises without deducting anything, on the understanding that a foreign invoice was a foreign matter. The exposure sat on the business, not on the suppliers. The work was to identify every payment in the period, separate the work performed in Canada from the work performed elsewhere, quantify what should have been withheld, and settle the remittances. It produced a corrected position for the open years and an invoice approval step that asks where the work was done.
Case study 3
Separating the fee withholding from the payroll withholding
A foreign engineering firm sent its own employees to a Canadian customer's site. Two deductions were running at once: the customer withholding on the firm's invoices, and the firm's obligation on the wages attributable to its employees' Canadian duties. Neither relief covered the other. The work was to set the two apart, apply for the relief appropriate to each, and hold a record of the days each person worked in Canada that supported both. It produced separate authorisations, a payroll that handled the Canadian duties correctly, and a customer prepared to pay the invoices without holding back.
Case study 4
Recovering a deduction where the waiver application came too late
An application for relief was lodged after the Canadian client had already paid and remitted, which meant there was nothing left for it to reduce. The work moved to the recovery route: establishing the income actually earned from the engagement, the expenses properly set against it, and the treaty position, then filing the Canadian return that measures the tax on the result rather than on the gross fee. It produced a filed return, the excess deduction claimed back, and a written note of when the application has to be started for the next engagement.
Case study 5
Recurring short visits and a waiver needed for each one
A specialist trainer visited Canadian clients several times a year, each visit a separate short engagement with a separate payer. Relief is engagement-specific, so one authorisation did nothing for the next booking and every client was deducting by default. The work was to build a repeatable file, holding the standard contract terms, the residence evidence and the record of days and locations, so an application could be prepared as soon as a booking was confirmed. It produced authorised relief on the bookings far enough ahead, and a process the trainer could run for each new one.
Case study 6
Working out how much of the fee was earned in Canada
A single contract covered design work carried out abroad and installation supervision carried out in Canada, and the Canadian client had deducted on the whole contract value. The question was not whether the regime applied but how much of the fee it applied to. The work was to apportion the contract by where the services were actually performed, evidence that from timesheets, travel records and the deliverables themselves, and put the apportionment to the client and into the filing. It produced a documented split, a smaller deduction on the remaining payments, and a claim for the rest.
Case study 7
A 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.
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Case study 8
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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