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Files that look like this one
Departure year rebuilt after a move to Hong Kong
A client had left Canada partway through a year and filed as though the move ended matters on the day the flight left. The ties told a different story: a house was still available and a spouse had not yet followed. We set out the facts as they were, settled on a defensible date of departure, prepared the departure return on that basis and disclosed the holdings that had to be listed. The engagement produced a documented residence position with its supporting evidence attached, and a consistent starting point for every year that followed.
Assignment package reconciled against the Canadian return
An employee posted to Hong Kong had been reporting the local payroll summary and nothing else. The assignment letter showed housing, schooling and home-leave items that the payroll line never carried. We rebuilt the compensation from the employer's own documents, worked out which elements belonged in the Canadian base for the period of residence, and prepared amended filings for the years affected. The work produced a corrected set of returns and a single schedule that the employer and the employee could both follow when the next year came round.
Foreign account disclosure brought up to date
A client with accounts and an employer retirement scheme in Hong Kong had never filed the Canadian disclosures, on the view that accounts paying almost nothing could not be reportable. We read the statements, established the cost of what was held, separated the holdings that had to be disclosed from those that did not, and prepared the outstanding filings. The engagement produced a complete disclosure record for the open years and a written note of which accounts have to be tracked from here on.
Hong Kong company reviewed for Canadian residence exposure
A founder living in Canada ran a company incorporated in Hong Kong and made every decision about it from where she lived. The risk was not the incorporation but the management. We documented where decisions were actually taken, who took them and how they were recorded, and set out what that meant for the company and for the money she was drawing. The work produced a written analysis of the residence question, a corrected characterisation of the withdrawals, and a record-keeping routine that supports the position rather than undermining it.
Returning family's first Canadian year prepared
A family came back to Canada after several years in Hong Kong, carrying accounts, a retirement scheme and a property they had kept. The question was not what they had earned but what they owned on the day they arrived. We established values at that date, set out the cost base Canada would recognise from then on, and prepared the arrival-year return on that footing. The engagement produced a documented opening position for every asset, which is the thing a later sale is measured against.
Double reporting untangled for a cross-border contractor
A contractor invoiced Hong Kong clients while spending most of the year in Canada, and had treated the income as outside the Canadian net because it was billed abroad. We traced where the work had been performed, which authority each receipt belonged to, and what relief was available for anything taxed on both sides. The work produced a reconciled set of figures, a claim for the relief that applied, and correspondence prepared in advance for whichever authority asked first.
A Group File That Had to Describe the Whole Group
The master file is a picture of the business rather than of one company, and it has to agree with what each local file says. Assembling it surfaces inconsistencies between entities that nobody had compared.
Read how this one runsA Trust Abroad With a Canadian Connection
Contributions or beneficiaries in Canada can bring a foreign trust inside the Canadian net entirely. The analysis is who contributed what and when, because the answer decides whether the trust files here at all.
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
Software revenue crosses borders by default — sourcing rules, withholding on licence-like payments and IP location decide the effective rate.
Software revenue is rarely taxed where the team sits. Licence, subscription and service income are characterised differently by each side, and the answer decides withholding at source, treaty relief and whether a foreign customer creates a taxable presence at all — questions that are cheap to settle before the contract and expensive afterwards.
- 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
