Case study 1
A reassessment for a year the client believed was closed
The notice arrived years after the return had been filed and accepted. Before addressing any of the adjustments, we established the date of the original assessment for that year, searched the file for any waiver, and set out what the sender was relying on to reopen it. The engagement produced a written chronology of the year, a documented position on the validity of the reopening, and an objection filed on that ground with the merits pleaded in the alternative. The client did not have to argue the figures first.
Case study 2
Matching a Canadian year to a late foreign reassessment
A foreign authority revisited a year long finished here and increased the tax paid abroad. The credit claimed on the domestic return was, from that moment, understated, and the domestic year sat outside the ordinary window for amendment. The work was to fix the foreign assessment as final, document the payment, and identify the route that remains available once a year is closed to routine change. The engagement produced a filed request supported by the foreign notice, and a schedule reconciling the two years to each other.
Case study 3
Reading a waiver signed years earlier and forgotten
The client had no memory of the document; the authority relied on it to reopen a year. We obtained the signed copy, read its description of the matters it covered, and compared that scope against the adjustments now proposed. Part of what was being reassessed sat outside the waiver. The engagement produced a documented position separating the items the year was genuinely still open for from those it was not, together with a note on revoking the waiver so that it would not carry the following year as well.
Case study 4
Unfiled years that had never started their clock
An emigrant assumed the years after departure had lapsed because nothing had arrived in the post. No return had been filed for them, so nothing had been assessed and no limitation period had begun to run. We worked out which years were genuinely outstanding, reconstructed the income from slips and foreign bank statements, and filed them as a set with an explanation of the departure. The engagement produced a complete filed record for those years, on terms the client chose rather than on the terms of a demand.
Case study 5
A refund the client could not reach in a closed year
The year could no longer be reassessed, and the client read that as protection. It also meant the overpayment sitting inside it was beyond ordinary amendment, because the refund window runs separately from the reassessment bar. We checked both dates, confirmed which had passed, and set out what remained: a discretionary relief request, judged on circumstances rather than granted as a right. The engagement produced that request, the supporting record of why the year had been filed as it was, and a candid view of the likely outcome.
Case study 6
Proving the history of a departure year to a buyer's lawyer
A property sale stalled because counsel wanted evidence of how an old departure year had been reported, and that year was long closed. Nothing could be changed in it, which was rather the point: the task was documentary instead of corrective. We retrieved the filed return, the assessment and the correspondence that followed it, then set them out as a single chronology with the source of each document identified. The engagement produced a documented history of the year that the lawyer could rely on, and the sale proceeded on it.
Case study 7
One Salesperson Abroad, and a Corporate Filing Obligation
A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to it.
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Case study 8
Trips That Added Up to a Filing Obligation
Short visits are tracked against a treaty threshold that is measured over a moving window rather than a calendar year. Where the threshold is passed, the obligation reaches back over the whole period.
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