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Ask us directlyTax Services Across Japan
What these engagements turn on
Toronto engineer seconded to Osaka on a long posting
The client took a posting to Osaka while his family remained in Canada and the family home stayed available to him. We worked through the residence question on those facts and concluded that he remained resident here, which meant the Japanese salary belonged on a Canadian return. We then matched Japanese national and local tax to the Canadian years the income fell in. The engagement produced Canadian returns for each year of the posting reporting the assignment income, a credit claim supported by the Japanese assessment notices, and a note of the employer-provided items that were a benefit here but not there.
Japanese manufacturer setting up a Canadian sales subsidiary
A Tokyo manufacturer incorporated a Canadian company to hold inventory and employ a small sales team. We registered the subsidiary for corporate filing and for payroll, reviewed the supply arrangements between it and the parent, and considered whether the parent's own visits and contract approvals created a presence of its own. Registration for GST and HST was settled on the basis of the supplies actually made in Canada. The engagement produced a filed corporate return for the first period, a running payroll arrangement for the Canadian staff, and a documented position for the parent.
Returning to Canada after several years working in Tokyo
The client had ceased Canadian residence when she moved to Japan and came back holding securities and a yen deposit account acquired while abroad. Property held when residence resumes is generally treated as acquired at that point, so the value on the day she returned is what her eventual Canadian gain is measured from. We fixed the date residence resumed and valued each holding as at that date. The engagement produced a recorded cost base for the portfolio in Canadian dollars, a first foreign property disclosure, and a return reporting income from the date residence resumed.
Japanese resident letting out a condominium in Canada
A client living in Tokyo owned a Canadian condominium let through an agent, with nothing being remitted to the Canadian tax authority. Rent paid to a non-resident is subject to withholding on the gross amount unless an election is made to be taxed on the net rent instead. We regularised the arrangement, made the election, and filed the outstanding non-resident returns with expenses and capital cost claims properly supported. The engagement produced a compliant withholding arrangement going forward, filed returns for the years in arrears, and a recovery of withholding that exceeded the tax actually due.
Recovering Japanese withholding on a departure lump sum
The client left Japan for Canada and received a lump sum from the Japanese pension system, paid net of withholding. The Canadian return was only half the problem, because the Japanese claim had to be made in Japan, through a representative appointed there, and within the period Japanese rules allow. We sequenced the two. The engagement produced the Japanese claim filed in time, a recovered portion of the withholding, and a Canadian return reporting the amount with credit for the Japanese tax ultimately borne rather than the tax originally deducted.
Shadow payroll for Tokyo staff working on a Canadian project
A Japanese employer placed staff on a client project in Canada while keeping them on the home payroll throughout. Duties performed in Canada bring withholding and reporting obligations on the employer, and relief has to be applied for rather than assumed. We reviewed each posting against the treaty conditions, applied for waivers where the conditions were met, and ran a shadow payroll for the postings where they were not. The engagement produced Canadian payroll registration, year-end reporting for each assignee, and a written test the employer now applies before agreeing a posting.
A Margin Defended With a Benchmarking Set That Fits the Facts
A comparables set is only as good as the screening behind it, and a rejected set takes the margin with it. The study selects the tested party first, screens on function rather than on industry code, and records why each comparable survived.
Read how this one runsOne Salesperson Abroad, and a Corporate Filing Obligation
A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to 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
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



