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Ask us directlyTax Services Across Australia
Cross-border tax case studies
Departure year split for a family relocating to Australia
A family left Canada partway through the year with a house still on the market and a child finishing a school term behind them. The year of departure is filed as a part-year return, and the date residence ends governs what falls inside it, including the deemed disposition that departure triggers on certain property. We fixed the date on the facts, valued the property concerned as at that day, and prepared the return. The engagement produced a filed departure year, a valuation file supporting the deemed disposition, and instructions for the Canadian-source income that continued afterwards.
Superannuation position documented before a first Canadian return
A client returning to Canada held an Australian retirement fund and wanted to know what to report while it was still growing and nothing had been drawn. The treatment depends on how the fund is characterised and whether growth inside it is recognised before payment, and that is not the same for every fund. We read the fund's own rules rather than assuming a type. The engagement produced a written position with its reasoning and supporting documents, a note of the alternative reading and why it was not taken, and a reporting routine for later years.
Rental income from a Canadian house reported after a move abroad
A client who had moved to Australia kept a Canadian property and let it, and the agent collecting the rent was deducting tax from the gross amount. Withholding on rent paid to a non-resident applies to the rent itself, not to the profit left after mortgage interest, insurance, agent's fees and repairs, so it commonly exceeds the tax actually due. An election allows the owner to be taxed on the net amount instead, with a return to follow. We made the election and set up the reporting, producing a lower deduction at source and a filed return recovering the excess.
Clearance obtained before a Canadian property sale completed
A seller living in Australia had already agreed a completion date before anyone raised the non-resident process. Withholding on a sale by a non-resident is applied to the sale price rather than the gain, and the purchaser is the party required to hold it back, so the timetable is not the seller's to set. We prepared the notification and the cost evidence and dealt with the queries that followed. The engagement produced a clearance certificate covering the disposition, release of the amount held beyond the certified figure, and the return that settled the gain.
Foreign tax credit rebuilt after mismatched income years
Australian tax had been claimed as a credit by taking the amount from an Australian assessment and entering it against a Canadian year, producing a claim neither authority could follow. The two income years do not run to the same calendar, so income and the foreign tax on it have to be apportioned onto the Canadian year before the credit limit can be worked out. We rebuilt the claim on that basis and documented the apportionment. The engagement produced a recomputed credit and an adjustment request for the years already filed.
A director in Australia and a Canadian company reviewed
A Canadian-incorporated company had drifted into being run entirely from Australia after its only active director moved there. Incorporation fixes one residence; where the real decisions are taken can fix another, and a company resident in both places relies on the treaty to settle which prevails, with obligations on both sides in the meantime. We examined how and where decisions were actually made rather than where the minutes said. The engagement produced a written residence assessment, a change to how board meetings are held and recorded, and a list of filings due while the position was corrected.
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.
Read how this one runsOne 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 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
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- 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
- 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
