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Ask us directlyTax Services Across Canada
What these engagements turn on
Part-year returns prepared for a family arriving in Canada
A family arrived in Canada partway through a year holding investments and a property abroad. The return had to separate the period before arrival from the period after, prorate the credits that depend on how long they were resident, and record the value of what they owned on the day they became resident so later disposals are measured from the right starting point. We prepared the arrival-year returns, the valuation schedule and a list of the reporting that begins the following year. The engagement produced filed returns and a documented cost base that will still be usable years from now.
Provincial allocation corrected for a business operating in several provinces
A corporation with premises in more than one province had been allocating all of its income to the province of its head office. Provincial corporate tax is apportioned by a formula that looks at where the salaries are paid and where the permanent establishments are, and the filed position reflected neither. We reviewed the payroll records and the leases, rebuilt the allocation, and amended the corporate returns for the years still open. The engagement produced corrected filings, an allocation schedule the bookkeeper maintains, and a memorandum explaining what creates a permanent establishment in a new province.
Foreign affiliate reporting caught up for a Canadian parent
A Canadian company had held a dormant subsidiary abroad for years without filing the annual foreign affiliate information return, on the understanding that a company with no activity had nothing to report. The obligation follows the interest, not the activity, and the exposure attaches to lateness. We mapped the group, established which entities fell within the definition, prepared the outstanding returns, and filed them with a request for relief setting out the circumstances. The engagement produced a complete set of filings, a settled position on the group structure and a reporting calendar tied to the corporate year end.
Sales tax position reviewed for a foreign marketplace seller
A business outside Canada selling through a marketplace to Canadian customers held stock in a Canadian fulfilment warehouse and had never considered registration. Holding inventory here changes the analysis, and the marketplace rules change who accounts for the tax on which sales. We mapped each supply from order to delivery, determined which were the seller's responsibility and which the marketplace's, registered where required and prepared the returns for the periods already elapsed. The engagement produced a registration, filed returns for the back periods and a written rule the client applies to each new sales channel.
Assignment payroll set up before staff arrived in Canada
A foreign employer was sending employees to a Canadian project and had assumed no Canadian payroll arose because the staff remained on the home payroll. Deductions generally follow the duties performed here, whichever entity issues the pay. We registered the employer, applied for waivers for the employees the treaty relieved, set the deductions for those it did not, and prepared the year-end slips. The engagement produced a compliant payroll from the first pay run, waivers on file for the relieved employees and a written procedure for the next group sent.
Departure and re-entry planned for a Canadian taking an overseas posting
A client accepted a posting abroad and wanted to know whether to sever residence or keep it. The two paths differ in almost every respect: continuing residence means worldwide income stays reportable here with credit for foreign tax, while severing means a departure return with a deemed disposition, withholding on the Canadian income that remains, and the end of the benefit programmes. We set both out side by side with the filings each requires, including what happens on the eventual return to Canada. The engagement produced a written comparison, a chosen course and a schedule of the steps in order.
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 runsThe Deemed Sale That Happens on Death
Canada treats most capital property as sold at fair market value on death, so a terminal return can carry tax on gains nobody realised. Valuations and the order of the returns are what decide the figure.
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
Cross-border tax for sellers shipping worldwide: marketplace withholding, foreign registrations and inventory nexus handled before they become audits.
Marketplaces withhold, remit and report in their own right, so the tax position of a single sale is decided by where the stock sat, where the buyer was and which platform collected — not by where the company is registered. We reconcile the platform's own filings against the returns before either is submitted.
- 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
- 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
