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Files that look like this one
A family arriving in Canada with accounts left behind
The starting point was an arrival date and a handful of bank accounts in the country the family had left. Nothing had been filed here yet. The work began with establishing the day residence started, because the return reports worldwide income only from that day, and the value of what they owned on that date sets the cost used when it is eventually sold. Statements were gathered for each account, converted, and split at the arrival date. The engagement produced a first Canadian return with a defensible residence start date and a written schedule of opening values, kept for the year those accounts are closed.
A company expanding abroad before deciding on a structure
The client asked for a corporate return and turned out to need a structure decision first. They had signed customers in another country and were about to hire there, with nothing in place beyond the Canadian company. The work consisted of setting out what each option would require in filings and withholding on both sides, rather than recommending one in the abstract, and then recording why the chosen route was chosen. The engagement produced a written structure note the directors could adopt, a calendar of the filings that route creates, and a quoted fee for the first year of them.
Withholding deducted at source on a payment covered by treaty
A payer abroad had deducted tax at its domestic rate on a payment that the treaty between the two countries treated differently. The client had assumed the deduction was final. The work was documentary rather than analytical: establishing residence for the year in question, obtaining the certification the payer's revenue authority required, and putting the claim in the form that authority accepts, within its own time limit for such claims. The engagement produced a recovered withholding and a process the client now runs before each payment instead of after it.
Back years filed for someone who had moved twice
The client had left one country, lived in a second, and returned, filing in none of them for the intervening period. Before anything was prepared we established residence year by year, because the answer changed twice and it decides which country taxes what. Slips were reconstructed from bank records where employers no longer existed. The returns were then filed in an order that allowed credit for tax paid abroad to be claimed against figures that were already final. The engagement produced a complete set of years for both countries and a closed correspondence file with each revenue authority.
Intercompany charges that had never been documented
Two related companies in different countries had been invoicing each other for management time for years, at an amount someone had settled on once. Nothing supported it. The work started with what the companies actually did for each other, established from staff time and contracts, and then with what an unrelated party would have charged for the same thing. The method was written up with the evidence behind it. The engagement produced transfer pricing documentation that exists as at the year it covers rather than assembled after a query, and a policy the group applies to the next year's invoices.
An estate holding property in two countries
The executor came to us after probate had started in one country and a bank in the other refused to release funds. The question was not the will but the tax clearances each jurisdiction wanted before assets could move, and which of the deceased's own filings were still outstanding. Final personal returns were prepared first, because the clearance applications depend on them. The engagement produced those final filings, the trust filings for the period the estate was administered, and clearance from both revenue authorities so the executor could distribute without personal exposure.
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 runsThe Deemed Sale That Happens on Death
Canada treats most capital property as sold at fair market value on death, so a terminal return can carry tax on gains nobody realised. Valuations and the order of the returns are what decide the figure.
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
