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International & Cross-Border Tax — Countries and Regions We Serve
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Ask us directlyFiles that look like this one
Filings reconciled for a household split across borders
One spouse had taken a post abroad while the other stayed with the children, and each had been advised separately in their own country. The advice did not agree: the same income was reported as taxable in one place and exempt in the other. We put both sets of filings side by side, identified where the treaty allocated each source, and worked out which return had to change. The engagement produced a single reconciled position for the household, amended filings where they were needed, and a note of how each future year should be prepared.
A treaty claim assembled before the payment left the payer
A payer abroad asked for documentation it could hold on file before releasing a payment, warning that without it the full domestic deduction would apply. Relief claimed in advance is a certificate and a form in the payer's hands; relief claimed afterwards is a repayment claim inside a foreign system, which takes far longer and can lapse. We obtained the residence certification and completed the payer's forms inside its deadline. The engagement produced payment at the treaty rate rather than the domestic one, and a template for every payment after it.
A file taken over midway after a local preparer withdrew
A client came to us with one country's return already lodged, the other half prepared, and the original preparer no longer contactable. We began by establishing what had actually been filed rather than what the client believed had been filed, obtained the transcripts, and tested whether the positions in the lodged return could be supported. The work consisted of completing the outstanding filing so that it agreed with the first, and correcting one entry in the lodged return that could not be sustained. It produced a matched pair of filings and a record of where every number came from.
Foreign income retranslated before a credit could be claimed
Income earned abroad had been converted at whatever rate the bank applied on the day funds were moved, which is not the basis a credit claim is tested on. Relief for foreign tax is limited to the Canadian tax on the same income, so both amounts have to be expressed on a consistent basis before that limit can be worked out at all. We retranslated the income and the foreign tax properly and recalculated the claim. The engagement produced a corrected credit computation with the conversion basis documented, and an adjustment request for the earlier year.
A move between countries planned before the departure was made
A client asked what to do about tax after accepting a post abroad, with several months still to run before the move. Planning before departure is a different exercise from cleaning up afterwards: the date residence ends, what is sold before that date and what is kept, which accounts and registrations are closed and which are not, can all still be chosen. We set out the consequences of each option. The engagement produced a dated sequence of steps to take before and after the move, and a written statement of the residence position the later filings would rest on.
Coordination between an overseas adviser and the Canadian filing
A client kept an adviser in the country he had moved to and wanted us only for the Canadian side, which is a workable split until the two sides make different assumptions about the same facts. We agreed in writing at the outset which of us decided residence, which figures would be exchanged, and in what order the returns would be prepared. Questions went between the two files rather than through the client. The engagement produced returns in both countries resting on the same facts, and a short protocol the client can hand to any future adviser.
Expanding Abroad — Branch or Subsidiary, Decided on the Numbers
The choice sets the tax on profits, the treatment of early losses, and what it costs to take money home later. The file models all three across the first years rather than deciding on the incorporation cost alone.
Read how this one runsInformation Returns Missed Behind a Correct Return
The heaviest exposure on a cross-border file is often a disclosure form rather than the tax. Where the return itself was right, the procedures for late information returns turn on a reasonable-cause narrative with dates and documents behind it.
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
Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.
Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- 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
