Value-priced Reg 105 or 102 waiver application — fixed-fee price

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Quoted in writing before the work starts. Reviewed with you before it is filed. From $999, quoted before work starts. Agreed in writing before the work starts. Value-priced reg 105 or 102 waiver application with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

+1 (416) 619-0068 See fixed fees
  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
  • Offices in India, the USA, Canada and the UAE
  • 15+ years of cross-border experience
  • Fixed fee agreed before work starts
The promise

Reg 105 or 102 waiver application is quoted as a fixed fee before any work begins, from $999 for a standard engagement. You review the finished work before it is filed, and if the scope changes we re-quote before continuing.

What the engagement actually covers

The waiver application prepared and filed before the payment or the assignment, with the treaty basis or the income-and-expense computation that supports it.

Two of the firm’s advisers and the team in the open-plan office

Three tiers

TierFixed feeWhat it covers
Standardfrom $999The straightforward case: one year, one country pair, records in order. Corporate cross-border filing at the published rate.
Complexfrom $999Additional filings travelling with the return, an advance application, or a second jurisdiction in the same set.
Multi-year or projectquoted on scopeMultiple years, a disclosure route or an entity structure. Priced per year and per entity and quoted before any work begins.

These are the fees on our own published schedule. The exact number for your engagement is confirmed in writing after the first call, and it is the number on the invoice.

What moves you up a tier

On this job specifically: Lead time. Applied for early the waiver removes the withholding; applied for late it does nothing for the payment that has already been made.

  • How complete the documents are when they arrive — a reconstructed year costs more than a documented one
  • Whether a foreign authority has to issue something before we can file
  • Whether an information return or a certificate application travels with the filing
  • Whether an entity is involved as well as an individual

What adds cost

The two cost drivers are the same on nearly every file: documents that have to be reconstructed, and steps that depend on a third party issuing something. Neither is a surprise if it is named at the quoting stage, which is where we name them.

The assumption we correct most often

That the withholding can be sorted out afterwards. It can be recovered afterwards, at the cost of a return and a year of waiting. The waiver is the cheap route.

What is never charged

  • The first call to the 24-hour helpline, where the scope is set
  • Re-sending a copy of a filing we prepared for you
  • Time spent telling you that you do not need the engagement

Get the quote

Bring the last two years of returns from each country involved, the slips or certificates for the income in question, and the dates — arrival, departure, or the transaction date. That is enough for us to tell you what has to be filed and what it will cost. Send us the facts and we will tell you what has to be filed and what it costs.

Request a fixed-fee quote

Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Published as general information. For a position on your own file, call the 24-hour helpline.

Corporate tax services — what this page covers

If you came here for corporate tax services, this is where it is dealt with. The subject is reg 105 or 102 waiver application, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.

The four phases of the work

  1. Send the documents as they are

    No tidying required — forward what you have and we tell you what is missing.

  2. Get a fixed quote in writing

    Priced from your actual documents before any work begins, not estimated after.

  3. Both countries prepared together

    One team builds the filings against each other so the relief lands exactly once.

  4. Review, then file

    You approve the finished work before we file it.

How reg 105 or 102 waiver application price is handled here

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

Key terms behind this page, defined

FEMA
India's exchange-control law, which defines residence differently from tax law and governs which accounts may be held and how funds may move.
Competent authority
The official body in each country empowered to apply and interpret a treaty, and to negotiate with its counterpart to resolve a case.
Situs
The location of an asset for tax purposes. It, not the owner's residence, decides whether an estate tax applies to a non-resident's holding.
Non-willfulness certification
The signed narrative that is the substance of a streamlined submission. A story that contradicts the filings is what turns relief into an examination.

Fixed fees around reg 105 or 102 waiver application price

Every card links a published fee with its scope spelled out — quoted in writing from your documents up front.

Corporate cross-border filing

$999fixed, before work starts

Covers: Corporate returns with foreign income, related-party reporting and cross-border structures, for companies of any size.

See this fee page

Payroll & mobility setup

$999fixed, before work starts

Covers: Employer registration and withholding for staff on assignment, arranged before the first pay run rather than corrected after it.

See this fee page

Non-resident & departure filings

$349fixed, before work starts

Covers: Returns for the year you leave, the year you arrive, and the years you earn rental or pension income from a country you no longer live in.

See this fee page

Why choose Legal Quotient for reg 105 or 102 waiver application price

You deal with the person who did the work

The practitioner who prepared and reviewed your file is the one who answers the question about it.

Both sides prepared together

Two returns built against each other by one team, so relief is claimed exactly once and nothing falls between the two systems.

Filed with the authority, not just prepared

The engagement runs to submission and to the correspondence that follows it, including the queries that arrive months later.

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

Two of the firm’s advisers at a desk in the Delhi office

How the engagement runs, phase by phase

Step 1

Establishing the facts

We establish what happened and when, because every position here is anchored to a date

Step 2

Agreeing the fee

A written scope and a fixed price, so you know the cost before committing

Step 3

Drafting and review

The filings are prepared, cross-checked against each other, and reviewed by name

Step 4

Filing and follow-up

You see the result, approve it, and we file it

The team reviewing a file together at a desk

How the work runs — quote first, then the work

  • Step 1: Hand over the paperwork in any state – Sorting it is our job. Send what exists and we identify what is missing from it.
  • Step 2: Priced before a single form is opened – The fee comes from the documents, agreed in writing, and stays where it was agreed.
  • Step 3: One position across every return – The same facts, filed consistently on each side, so nothing contradicts anything else.
  • Step 4: Filed after you have read it – The completed work reaches you before it reaches an authority.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

The rest of this practice

Browse sideways: the pages below answer the neighbouring questions.

The work we do for clients like this

Form 8832 — entity classification election Form 8832 entity classification election — the guide, the FAQ and the fixed fee.
Canadian company expanding to the US — LLCs and global taxes The full guide to global taxes LLC, with the fee fixed before any work starts.
Share buyback and capital reduction tax Its own page: share buyback and capital reduction tax — mechanism, deadlines and published fees.
Form 2350 — extension for citizens abroad Everything on form 2350 extension abroad, at the same depth as this page.
Lower or nil TDS certificate under section 197 Lower nil TDS certificate section 197 — the guide, the FAQ and the fixed fee.
Intercompany agreements The full guide to intercompany agreements, with the fee fixed before any work starts.
India ↔ United Kingdom — DTAA Its own page: India ↔ United Kingdom — DTAA — mechanism, deadlines and published fees.
State payroll & nexus for remote staff Everything on state payroll & nexus for remote staff, at the same depth as this page.
Schedule TR — tax relief claimed (India) Schedule tr India — the guide, the FAQ and the fixed fee.

Who we bring this work to

Tax for cross-border truck drivers Cross-border truck drivers tax — the guide, the FAQ and the fixed fee.
Seafarers & mariners — your filing calendar The full guide to seafarers & mariners your filing calendar, with the fee fixed before any work starts.
Management consultants — what you owe in each country Its own page: management consultants what you owe in each country — mechanism, deadlines and published fees.
Non-resident landlords — your filing calendar Everything on non-resident landlords your filing calendar, at the same depth as this page.
Engineering firms cross-border tax Engineering firms cross border tax — the guide, the FAQ and the fixed fee.
Software developers — what we charge The full guide to software developers what we charge, with the fee fixed before any work starts.
Freight forwarders cross-border tax Its own page: freight forwarders cross border tax — mechanism, deadlines and published fees.
Tax for non-resident landlords Everything on non-resident landlords tax, at the same depth as this page.
Investment funds cross-border tax Investment funds cross border tax — the guide, the FAQ and the fixed fee.

The corridors we work every week

Seychelles tax for expats — country guide Seychelles tax for expats — the guide, the FAQ and the fixed fee.
Ukraine tax for expats — country guide The full guide to Ukraine tax for expats, with the fee fixed before any work starts.
Ecuador tax for expats — country guide Its own page: ecuador tax for expats — mechanism, deadlines and published fees.
Luxembourg tax for expats — country guide Everything on Luxembourg tax for expats, at the same depth as this page.
Germany tax for expats — country guide Germany tax for expats — the guide, the FAQ and the fixed fee.
US–UAE tax corridor The full guide to US UAE tax, with the fee fixed before any work starts.
Qatar tax for expats — country guide Its own page: Qatar tax for expats — mechanism, deadlines and published fees.
India–United Kingdom tax corridor Everything on India United Kingdom tax, at the same depth as this page.
France tax for expats — country guide France tax for expats — the guide, the FAQ and the fixed fee.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

Cross-border situations we are engaged for

Case study 1

Fifteen Per Cent Held Back From a Fee for Services in Canada

A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.

Read how this one runs
Case study 2

Withheld at the Statutory Rate When a Treaty Rate Applied

Where withholding has already gone out at the full domestic rate, the treaty rate is recovered rather than applied. The file establishes entitlement for each payment, then puts the documentation in place so the following year runs at the correct rate from the start.

Read how this one runs
Case study 3

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 runs
Case study 4

A Foreign Subsidiary That Nobody Had Been Reporting

Owning a company abroad triggers an information return separate from the corporate return, with its own penalty. The work is the surplus and income computations behind it, which also determine how a future dividend is taxed on the way home.

Read how this one runs
Case study 5

Branch or Subsidiary, Decided Before Incorporation

The choice changes where profits are taxed, what has to be filed, and whether losses in the early years are usable. It is difficult to reverse once trading has begun, so it is modelled first.

Read how this one runs
Case study 6

The Year of Leaving India

The departure year carries a transition status with its own treatment of foreign income, and the position for the following years follows from how it is set. Getting the first year right saves arguing about the rest.

Read how this one runs
Case study 7

The Local File That Has to Match the Accounts

A local file describes the entity's own controlled transactions and ties them to its statutory figures. Where the two do not reconcile, that is what an examiner opens with.

Read how this one runs
Case study 8

Unreported Foreign Income Disclosed Before the CRA Asked

A voluntary disclosure has to be genuinely voluntary — once a letter arrives, the route usually closes. The engagement establishes whether the programme is still available, prepares the years, and puts the relief request in with the filing rather than after it.

Read how this one runs

All case studies — every published engagement in one place.

How and where the work is delivered

Every link below is a full page of its own — the same depth as this one, for its own subject.

Where the work is delivered

More coverage detail

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

Treaty residency & tie-breaker
FATCA reporting (Form 8938)
Foreign tax credit (Form 1116)
Multi-country filing calendar
Real estate holding structures
International tax planning
Pre-immigration tax planning
Family office structures
One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Form 1040 from abroad
US state non-resident returns
FBAR (FinCEN 114) filing
Form 5472 — foreign-owned US corp
FIRPTA withholding (Form 8288)
US estate tax exposure
IRS streamlined foreign offshore
PFIC reporting (Form 8621)
Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

Departure tax leaving Canada
T1161 properties on emigration
Residency planning
Step-up in cost base on arrival
Split-year residency
Employment income under a treaty
Social security totalization
Returning to Canada after years abroad
The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Section 216 rental return
NR4 & NR6 withholding
Section 217 pension return
Section 116 clearance certificate
Regulation 105 waiver
Non-resident employment income
Taxable Canadian property
Part XIII withholding review
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

s.247 contemporaneous documentation
Functional & risk analysis
Benchmarking study
Intercompany agreements
Country-by-country report
BEPS & Pillar Two
Permanent establishment risk
TP audit defence file
Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Cross-border wills
US estate tax for non-resident aliens
Terminal return & clearance certificate
Non-resident trusts (s.94)
T1141 & T1142 trust reporting
Inheriting property abroad
Graduated rate estates
Post-mortem planning & pipeline
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Entity selection across borders
Business profits & PE
Intercompany loans & thin cap
Paying dividends to a foreign parent
Global mobility & day tracking
Debt vs equity funding
Branch or subsidiary
Cross-border M&A due diligence
Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

NRI residency day tests
NRE, NRO & FCNR accounts
TDS on property (s.195)
Lower or nil TDS certificate
Repatriating sale proceeds
Capital gains on Indian shares
India–Canada DTAA
ITR-2 for NRIs
The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

T1135 foreign property
T1134 foreign affiliates
Departure tax
Newcomer's first return
Returning to Canada
Split-year residency
US citizens in Canada
Canada–US corridor
Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

Expat tax in the UAE
Moving to the UAE
Moving back from the UAE
UAE property purchases
Retiring in the UAE
Canada–UAE corridor
India–UAE DTAA
US–UAE corridor
A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Cross-Border Real Estate

Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.

Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.

  • Section 216 rental returns
  • FIRPTA withholding recovery
  • Section 116 clearance
  • Treaty credit optimization
Explore Real Estate

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Reg 105 or 102 waiver application pricing — questions we are asked

What is included in the fee for reg 105 or 102 waiver application?

The waiver application prepared and filed before the payment or the assignment, with the treaty basis or the income-and-expense computation that supports it.

What would make reg 105 or 102 waiver application cost more than the standard tier?

Lead time. Applied for early the waiver removes the withholding; applied for late it does nothing for the payment that has already been made.

Is the fee really fixed?

Yes, for the scope quoted. If the scope changes — another year appears, an entity turns up, a certificate becomes necessary — we re-quote before doing the work, so there is never an invoice you have not already agreed to.

Is dividend income from Indian shares taxable for an NRI?

Yes. Dividends are taxed in the shareholder's hands, and the paying company withholds on payment to a non-resident. The treaty can reduce that withholding, but only if the documents are with the company before it pays: a tax residency certificate from your country, Form 10F, and a PAN on the register. Without them the domestic rate applies and your route back to the difference is a refund claim on an Indian return. See residency certificates and Form 10F.

What is a section 217 return and should I file one?

An election available to a non-resident receiving certain Canadian pension and benefit payments. Normally those payments suffer flat withholding and that is the end of it. Under the election you file a Canadian return and are taxed on that income at graduated rates as though resident, which produces a refund of part of the withholding where the graduated result is lower — and no benefit where it is not. It is worth modelling before electing, because the choice is annual. See the section 217 return.

What are Forms 15CA and 15CB for?

They clear a payment out of India. Form 15CA is the remitter's declaration of the payment and the tax withheld on it; Form 15CB is an accountant's certificate on the taxability of the amount, the treaty article relied on and the correct withholding rate. The bank generally will not execute the transfer without them, in the categories where they are required. The work is deciding the rate correctly, because the certificate is the record of that decision. See 15CA and 15CB certification.

Tax terms explained

Totalization agreementPFICWithholding certificatePlace of effective managementClearance certificateRegulation 102Form 3CEBDay-count recordDual citizenshipFIRPTAWithholding agentTreaty overrideGIFT CityForeign affiliate Browse the full A–Z glossary

Related fixed fees and services

Related in this section

All pricingT106 information return — fixed-fee priceMaster file & CbCR — fixed-fee priceTP benchmarking study — fixed-fee priceForm 3CEB certification (India) — fixed-fee priceCross-border payroll setup — fixed-fee priceGST/HST non-resident registration — fixed-fee price

Connected engagements

Hiring an employee in another countryWinding up a foreign subsidiaryCountry-by-country reportIndian TP documentation & Form 3CEBPaying dividends to a foreign parentPaying interest on a shareholder loan abroad

Pricing for this work

T1134 foreign affiliate reporting — fixed-fee priceT106 information return — fixed-fee priceUS return from abroad (1040 + 2555/1116) — fixed-fee priceReg 105 or 102 waiver application — fixed-fee price
No hourly billing, ever

Talk to us about reg 105 or 102 waiver application

One short call, one fixed quote in writing, and your approval before anything is filed.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Offices in India, the USA, Canada and the UAE
  • A named reviewer signs off every filing
  • Rated 5.0 out of 5 stars on Google

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

Request a Quote +1 (416) 619-0068