Cross-border tax terms — W
7 terms beginning with W, each defined at mechanism level.
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What each entry gives you is the mechanism: the condition that triggers the term, and the consequence that follows. Amounts and rates belong on the filing pages, where they carry a tax year and a source.
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. Each term page therefore says what the word means, why it bites, and which of our pages it actually changes.
If a term like this is in a notice you have received, bring the notice. The definition matters far less than what the sender is actually asking for. Every page here carries the name of the person who reviewed it and the date they did.
- Worldwide income — All income wherever it arises.
- Withholding tax — Tax collected by the payer at the moment of payment, on the strength of the documentation the payer holds.
- Withholding agent — The person required to withhold and remit.
- Withholding certificate — An advance determination reducing withholding on a transaction to the tax actually expected — worth many times more applied for before closing than after.
- Wrapped asset — A token representing another asset.
- Wash sale — A sale and repurchase intended to realise a loss, restricted by rules in several systems including superficial-loss provisions.
- W-8BEN — The individual certificate of foreign status given to a US payer to claim a treaty rate.
What the W entries have in common
7 terms begin with W. The term below is defined in full on its own page, alongside the filings it governs and the fee for dealing with them. Three to start with: Worldwide income, Withholding tax and Withholding agent.
Nearby letters
V — 2 terms · Z — 1 term. The full A–Z lists all 297 terms in one place.
Back to the full glossary · Cross-border tax answers · Side-by-side comparisons
Files that look like this one
Withholding tax rate corrected after a payer applied the wrong treaty rate
A Canadian payer had been applying the default domestic withholding tax rate to payments to a foreign recipient, without checking whether a lower rate applied under the relevant treaty. We confirmed the recipient's treaty eligibility, supplied the documentation the payer needed, and the withholding rate was corrected going forward rather than the recipient having to claim a refund on every payment.
W-8BEN prepared to establish a Canadian resident's reduced US withholding rate
A Canadian resident receiving US-source investment income was having the full US domestic withholding rate applied because no W-8BEN had ever been filed with the US payer establishing their foreign status and treaty eligibility. We prepared the form with the correct treaty claim, the client's broker updated its withholding accordingly, and future payments reflected the reduced treaty rate rather than the default domestic one.
Worldwide income position reviewed for a client who assumed only Canadian income counted
A Canadian resident assumed only their Canadian-source income needed to be reported, unaware that residents are generally taxed on worldwide income regardless of where it is earned. We reviewed the client's foreign income sources, prepared the return reporting worldwide income correctly with the appropriate foreign tax credits applied, and corrected the client's understanding of the underlying rule for future years.
An Adjustment in One Country and No Relief in the Other
A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.
Read how this one runsA Canadian Working in the US on a Work Visa
Immigration status and tax residence are different tests, and a visa says nothing about which country taxes the salary. The file fixes residence, applies the employment article, and sequences the two returns so the credit lands where it is usable.
Read how this one runsThe Same Income Taxed Twice on Paper
Relief usually exists and is lost to sequence: one country taxes at source and the other credits it, and preparing them in the wrong order claims a credit against a figure nobody has computed.
Read how this one runsA Student or Researcher Covered by a Treaty Article
Several treaties carry a dedicated article for students, trainees and visiting researchers that displaces the ordinary employment rules. Whether it applies turns on the purpose of the stay and the source of the funds, both of which are evidenced rather than asserted.
Read how this one runsA Taxable Presence Created Without an Office
A dependent agent habitually concluding contracts can create a permanent establishment where there is no premises at all. The review tests what the person actually does against what the treaty describes.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Performance income is taxed where earned — Regulation 105 in Canada, withholding agreements in the U.S. — with special treaty articles overriding the usual rules.
Performance income is taxed where the performance happens, and the deduction is usually taken at source on the gross fee before expenses. Recovering the difference is a filing exercise in the other country, and it only works if the tour, the residency and the withholding certificates were documented while the work was being done.
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
