Everything we publish, in one place
Free to read, nothing to fill in first. Rates and thresholds state the tax year they apply to, and anything we are not certain of is described rather than quoted.
Free e-book library
Long-form guides on the filings this practice runs every day — departure years, dual filings, transfer pricing files, cross-border estates. Free to read, no email gate.
21 guides
Open free e-book libraryTax calculators
Work out corporate tax, personal tax, and salary against dividends before you commit to anything. Every figure states the tax year it uses.
25 calculators
Open tax calculatorsCross-border tax answers
Direct answers to the questions people actually arrive with — late filings, foreign property, departure tax, treaty positions.
808 answers
Open cross-border tax answersCross-border tax glossary
Plain definitions for the terms the CRA and the IRS use without explaining, each one linked to the pages where it matters.
322 terms
Open cross-border tax glossaryCountry corridors
What changes when money, work or residence crosses one specific border, corridor by corridor rather than country by country.
25 corridors
Open country corridorsSide-by-side comparisons
Two regimes, two structures or two filing routes set against each other, so the trade-off is visible before you pick one.
31 comparisons
Open side-by-side comparisonsArticles
Longer pieces on rules that changed, deadlines that moved, and filings that go wrong in a predictable way.
60 articles
Open articlesWant one of these applied to your own file? The helpline is open 24 hours, the fee is agreed in writing before any work starts, and 18,000+ clients have already been through the process. Book a consultation.
What these engagements turn on
A reader who arrived with the departure guide half worked through
Someone leaving Canada had read the departure year guide, listed their assets and stopped at the deemed disposition. The work started from their own list rather than from a blank page, which shortened it considerably. Holdings were sorted into what is deemed disposed on departure and what is excluded, valuations were obtained for the items that needed them, and the elections available to defer were weighed against the security they call for. The engagement produced the departure return, a schedule of values as at the departure date, and the election paperwork filed with it.
Choosing a structure after reading the business and structure guides
A founder with customers in two countries had read through the business and structure section and arrived with the right question rather than a preferred answer. The work was to test the options against their actual facts: where the work would be performed, where the customers contract, which entity would hold the intellectual property, and what each choice would cost in annual compliance. The engagement produced a written comparison of the structures considered, a recommendation with its reasoning recorded, and a registration and filing calendar for the structure that was chosen.
An unreported account found by a reader of the disclosure guides
A reader working through the reporting and disclosure guides recognised an account they had never mentioned to anyone. The first task was establishing the span of years affected and whether the income had in fact escaped tax, because the reporting failure and the tax position are separate questions with separate consequences. Statements were requested from the institution and the income was recomputed for each year. The engagement produced amended returns, the outstanding information reports, and a submission explaining how the omission arose, prepared before any approach was made to the authority.
An executor sequencing two countries after reading the estates guide
An executor had read the estates and inheritance material and understood that the order of the filings mattered, but not what that order was for this particular estate. The work was to map every asset to the jurisdiction that would tax it, fix the dates each filing runs from, and identify which return had to be settled before another could claim relief for the tax it paid. The engagement produced a filing calendar for the estate, the returns prepared in that sequence, and a note to the beneficiaries setting out what remained outstanding.
A secondment set up from the payroll and mobility guide
A business sending an employee across a border had read the payroll and mobility guide and knew that a certificate has to be obtained in advance, which is the part most callers have already missed by the time they telephone. The work was the application itself, together with payroll instructions for both entities so that contributions and withholding stopped in one place and started in the other on the same date. The engagement produced the certificate, written payroll instructions for each side, and a note covering what happens if the secondment is extended.
From the transfer pricing guide to the local file itself
A finance director had read the transfer pricing guides and recognised the arrangement described in them as their own. The conversation could therefore begin at scope rather than at explanation. The transaction types were listed, the entity to be tested was agreed, and the level of defensibility required was settled before a fee was set. The engagement produced a functional analysis, a benchmarking search with its rejection reasons recorded as they were made, and a local file covering the year in question, with the working papers kept for a refresh the following year.
Residency Changed Mid-Year and Both Returns Assumed a Full One
A move part-way through a year produces two part-year positions, not two full ones. The engagement establishes the date residence actually changed, allocates income either side of it, and amends whichever return was filed on the wrong footing.
Read how this one runsA 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 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
- 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
Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.
Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.
- 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
