Cross-border tax terms — S

These entries describe how a term works rather than what it is worth in a given year. That is deliberate — figures move, and a figure remembered from a definition is the kind that ends up on a return unchecked.

Terminology is where cross-border risk hides. The rate is visible and gets checked; the classification is invisible and does not, which is why the classification is what usually goes wrong. Every entry closes with the filings it touches, because a definition you cannot attach to a form is not yet useful.

The question worth asking is not what a term like this means but whether it applies to you this year. That is a computation on your facts. Every page here carries the name of the person who reviewed it and the date they did.

• Sojourner rule — A rule that makes a visitor resident for a whole year by reason of days spent in the country, regardless of ties.
• Substantial presence test — The US day-count test for residence.
• Split-year treatment — The mechanism by which a year of arrival or departure is divided into resident and non-resident periods for reporting, even though the year itself remains one tax year.
• Source income — Income treated as arising in a particular country by that country's sourcing rules.
• Saving clause — A treaty provision preserving a country's right to tax its own citizens and residents as if the treaty did not exist, which is why many articles do less for a US citizen than they appear to.
• Section 195 TDS — India's obligation on a payer to deduct tax from a sum chargeable in India paid to a non-resident, with the payer liable if the determination is wrong.
• Specified foreign financial asset — The class of asset reportable on the US FATCA statement: foreign accounts, foreign-issued securities, interests in foreign entities and certain foreign contracts.
• Specified foreign property — The class of property reportable on Canada's foreign property statement.
• Surplus accounts — The per-affiliate pools that decide how much of a foreign dividend arrives in Canada untaxed.
• Subpart F income — Categories of a controlled foreign corporation's income taxed currently to its US shareholders, regardless of distribution.
• Schedule FA — The foreign asset schedule of the Indian return.
• Schedule FSI — The Indian schedule reporting foreign-source income and the tax paid on it, country by country, from which the foreign tax credit claim is built.
• Section 216 — The Canadian elective return that taxes a non-resident's net rental profit at graduated rates instead of gross rent at the flat withholding rate.
• Section 217 — The Canadian elective return for a non-resident receiving pension and similar periodic amounts, worth making only when the graduated result beats the flat withholding.
• Section 116 clearance — The certificate the CRA issues on a non-resident's disposition of taxable Canadian property, without which the purchaser holds back part of the price.
• Section 247 penalty — Canada's transfer-pricing penalty, which contemporaneous documentation is designed to prevent.
• Secondary adjustment — A follow-on characterisation of the money that never moved after a transfer-pricing adjustment — often a deemed loan or dividend, with interest or withholding.
• Safe harbour — A prescribed margin or method that a taxpayer may adopt for certainty, generally set above what a study would support.
• Service PE — A permanent establishment created by furnishing services in a country for a period.
• Subsidiary — A separate company in the foreign country, which ring-fences liability and creates withholding, transfer pricing and a second set of accounts.
• Substance-based income exclusion — A carve-out in the global minimum tax rules that removes a return on payroll and tangible assets from the top-up base.
• Situs — The location of an asset for tax purposes.
• Section 94 trust — A trust deemed resident in Canada because of a resident contributor or beneficiary, bringing its income into the Canadian base.
• Streamlined foreign offshore — The US catch-up route for non-willful filers living abroad, requiring back returns, account reports and a signed non-willfulness certification.
• Streamlined domestic offshore — The US catch-up route for non-willful filers resident in the United States, which carries a penalty computed on the unreported asset values.
• Statute-barred year — A year the authority may no longer reassess.
• Simplified registration — A sales-tax registration route for non-resident digital suppliers that is easier to operate and gives no input tax recovery — the wrong trade for a business with local costs.
• Shadow payroll — A host-country payroll that pays nobody, existing so the host receives the withholding and reporting due on compensation paid elsewhere.
• Secondment — An arrangement placing an employee with another group entity.
• Stock option benefit — The employment benefit arising on an option, sourced across the period between grant and vest so two countries can tax slices of one gain.
• Sourcing by workdays — The apportionment of employment income and equity gains by reference to days worked in each country — reproduced from a travel record, not from memory.
• Self-custody — Holding crypto without an intermediary, which is treated differently from a custodial holding under several reporting regimes.
• Staking reward — Consideration received for participating in a network, generally an income event valued at receipt and becoming the cost base for a later disposal.
• Superficial loss — A denied loss where the same or identical property is reacquired within a defined period around the sale by the taxpayer or an affiliated person.
• Secure portal — An access-controlled channel for tax documents, used because tax records are the most sensitive papers most people own.
• Scope boundary — The written line between what we do and what another adviser keeps, agreed at the start so nothing is duplicated or dropped.
• Second opinion — A review of a filed position, which most often finds an unclaimed credit, a missed information return and an undisclosed treaty position.
• Streamlined filing — The US catch-up route for non-willful filers, requiring a limited number of back returns and account reports plus a signed certification.
• Section 116 certificate — The Canadian clearance certificate on a non-resident's disposition of taxable Canadian property.

What the S entries have in common

39 terms begin with S. 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: Sojourner rule, Substantial presence test and Split-year treatment.

Nearby letters

R — 16 terms · T — 28 terms. The full A–Z lists all 297 terms in one place.

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