What is included in the fee for t106 information return?
The related-party transaction return, reconciled to the corporate return and to the non-resident slips so the three tell one consistent story.
What would make t106 information return cost more than the standard tier?
Inconsistency between the three filings. Where the return, the slips and the schedules disagree, resolving the difference is the engagement rather than the filing.
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.
Does T106 need to be filed even if the related-party transactions were priced at fair value?
Yes — the filing requirement is triggered by the existence and volume of non-arm's-length transactions with non-residents, not by whether the pricing was ultimately arm's length, so the return is required regardless of whether the transactions themselves would survive a transfer-pricing review.
What counts as a reportable transaction on T106?
Transactions with non-resident related parties above the reporting threshold — sales, purchases, services, rents, royalties and similar dealings — are captured, and each category and each counterparty generally needs its own schedule rather than one combined figure.
Does a late T106 filing carry its own penalty separate from any transfer-pricing adjustment?
Yes — the information-return filing itself carries its own penalty exposure for being late or incomplete, independent of whether the underlying transfer pricing is later found to need adjustment, so the two risks are distinct and both need to be managed.
How does T106 relate to a company's Form 3CEB or equivalent foreign filing?
They serve similar disclosure purposes in different countries, and a group with related-party transactions crossing both Canada and another jurisdiction with its own equivalent filing needs both prepared consistently, since the same underlying transactions should be described the same way in each.
Does GILTI apply to individuals?
Yes, and it lands harder on them. An individual US shareholder of a controlled foreign corporation has the same inclusion a corporate shareholder does, but without an election gets neither the corporate-level deduction nor credit for the foreign corporate tax already paid — so foreign profit can be taxed at individual rates with no relief for tax the company paid abroad. An election to be taxed as though through a domestic corporation is usually the first thing to model. See Form 5471 and CFCs.
Are foreign trusts taxable in Canada?
They can be. Canada's deemed-resident-trust rules can pull a non-resident trust into the Canadian tax system where there is a resident contributor or, in some cases, a resident beneficiary — taxing it as though it were resident here. Separate reporting applies to transfers or loans to a non-resident trust and to distributions and debts from one. The planning point is that contributing to an offshore trust from Canada rarely achieves what the brochure suggests. See non-resident trusts.
