Case study 1
Reviewing two returns that had never been read together
Returns for the same year had been prepared in two countries by two firms, each competent and neither holding the other's file. Foreign tax paid on one side had not been claimed as a credit on the other, because the preparer had not seen evidence of payment and had not been asked for it. We read both returns side by side against the source documents, established what had been paid and when, and prepared the amendment with the proof attached. The engagement produced a recovered credit for the open years and a document pack each preparer now receives before filing.
Case study 2
A review that found an information return nobody had requested
A client held an interest in a foreign corporation, had filed complete personal returns for years, and had never been asked about the company. The missing item was the information return that reports an interest in a foreign corporation, which reports rather than pays, so nothing on the filed returns pointed to its absence. We established the ownership history from corporate records, identified the years in which the interest was held, and settled the correction route before anything was filed. The engagement produced the outstanding information returns for those years, filed in an order agreed in advance, and a written note of the position taken.
Case study 3
A treaty position that was right but never disclosed
The tax on the return was correct. The reason it was correct was a treaty article the preparer had applied to the calculation and disclosed nowhere on the form, so the return read as though domestic law had produced the figure. We identified the article actually relied on, checked that the facts supported it, and made the disclosure for the open years. Nothing about the tax changed. The engagement produced returns that state the position they depend on, and a short memorandum recording the supporting facts while they were still easy to obtain.
Case study 4
Ordering the corrections so the relief was not lost
A client had discovered unreported foreign accounts and wanted the most recent return amended immediately. We stopped the amendment. Relief on this kind of correction depends on the route taken and on what is disclosed with it, and a quiet amendment filed first can foreclose the route that carries relief. We reviewed the whole period, established how the omission had arisen, and prepared the correction as a package including the signed certification the route requires. The engagement produced a complete set of years filed together with that certification, rather than an amendment with no explanation attached.
Case study 5
A transfer from abroad that was reported nowhere
A family transfer from relatives overseas had been treated as a non-event because it was not income, and in the client's own return it was not. The reporting obligation sat on a separate information return for gifts and distributions received from abroad, which nobody had raised. We established the source, the dates and the character of the transfer from bank records and family correspondence, separated the part that was a gift from the part that was a distribution, and filed the outstanding returns. The work produced a reported history the client can point to if the funds are ever questioned.
Case study 6
A review that confirmed the return and changed nothing
A study permit holder had filed on the assumption that the permit itself decides residence, and wanted the returns amended. The review found the filed position defensible on the facts, since the ties recorded in the file supported it, and that amending would have replaced a supportable position with a worse one. We documented the residence analysis properly, noted the facts it turns on, and identified which change in circumstances would alter it. The engagement produced no amendment at all: a written, dated residence position, and a note of what to re-examine if the situation changes.
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.
Read how this one runs
Case study 8
One Salary, Two Countries Claiming It
A US citizen resident in Canada, taxed in full on both sides because each return was prepared without the other in view. Deciding which country has the first right to the income, then claiming relief on the second return in the right order, is what stops the same dollar being taxed twice.
Read how this one runs
