Case study 1
Sorting a consolidated statement into the class and its carve-outs
A client brought a single consolidated statement running to dozens of pages and asked whether he had a reporting problem. The statement mixed registered accounts, ordinary accounts and two holdings abroad, which is why nobody had been able to answer him. We rebuilt it as a list of individual holdings, marked each one as inside the class or outside it, and wrote the reason against every exclusion. The engagement produced a schedule that answered the question for the year, showed which holdings had driven the answer, and could be updated each year rather than rebuilt.
Case study 2
Foreign shares in a domestic brokerage account left off for years
A client had reported her foreign bank accounts carefully and omitted a large holding of foreign shares because it sat with a Canadian broker and the statements arrived in Canadian dollars. Where the account is held is not what the class turns on. We identified the issuer of each security in the account, separated the foreign-issued holdings from the domestic ones, and tested the years accordingly. The engagement produced a holding-by-holding classification of the account, the years in which the omission mattered, and corrected statements for those years.
Case study 3
A family property abroad that answered the question differently each year
A client owned a house in another country that his parents lived in, and which was let to tenants for part of the period under review. Use is central to how the carve-outs apply, so a single answer for the whole period was never going to be right. We built a timeline of occupation and letting from tenancy agreements, utility accounts and the client’s own travel, and tested each year on the facts of that year. The engagement produced a year-by-year position on the property with the evidence for each year attached to it.
Case study 4
Establishing whose share a joint account abroad actually was
An account abroad stood in the names of a client and her brother, and each had assumed the other was dealing with it. Neither had reported it. The class attaches to the property held, so the first task was to establish what each of them held rather than to split it down the middle. The account opening documents, the source of the deposits and the pattern of withdrawals told a consistent story. The engagement produced a documented conclusion on the client’s share, statements for the years affected, and a basis her brother’s own advisers could work from.
Case study 5
Registered holdings set aside before the remainder was tested
A client had been filing the foreign property statement for years on the strength of a total that included everything foreign on his consolidated statements, registered accounts among them. Property inside Canadian registered plans is treated differently, and once those accounts were separated out the picture changed substantially. We split the holdings by account type, tested only the holdings outside the plans, and documented the split. The engagement produced a corrected schedule for each year under review and a note of which accounts had been excluded and on what basis.
Case study 6
Fixing the year an unwound estate became property he held
A client’s father had died abroad some years before the estate was distributed, and the client had been told, variously, that he should have reported from the date of death and that he need not report until the money arrived. Neither date was the right one. We worked from the will, the grant and the executor’s correspondence to fix when the property became his, and built the schedule from that year. The engagement produced a dated conclusion on when the holding began, the documents supporting it, and statements for the years from that point.
Case study 7
A Canadian Landlord With Property in the United States
Gross withholding on US rents takes no account of mortgage interest, tax or repairs, so a leveraged property can face tax on turnover. An election onto net basis fixes that, and it has its own timing and its own filing.
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Case study 8
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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