374 pages. Every situation we file for, by the situation rather than by the form. Each one opens with the part that applies to that situation and nowhere else — a threshold, a treaty article, a filing that one group owes and the group beside it does not — and works one example through in full.
Cross-border and international tax services
Every situation we file for, by the situation rather than by the form.
- 15+Years of the founder's cross-border experience
- 18,000+Clients served across our offices in India, the USA, Canada and the UAE
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- 4Global offices — India, USA, Canada & UAE
Secure a fixed quote
Start by sending whatever paperwork exists — a written fixed quote comes back before any work begins.
24-hour helpline: +1 (416) 619-0068374 pages in this section. Every situation we file for, by the situation rather than by the form.
Every page in this section is written to the same standard: it opens with the block that exists nowhere else on the site — a threshold, a treaty article, a rule that applies to one group and not the one beside it — and it carries one worked example, worked through in full rather than a set of generalities.
Where a page needs a statutory threshold, a rate or a day-count, that figure is verified against the issuing authority before it ships. Where it cannot be verified for the year in question, the page states the mechanism and quotes no number, because a wrong threshold on a page like this is worse than no page at all. Every statutory page also carries the name of the person who reviewed it and the date they did.
Fees are fixed and agreed in writing before any work begins, and you review the finished work before it is filed. Documents move through a secure portal and you can meet us at any of our offices, so where you are makes no difference to how it works.
Showing all 374 pages.
Individual situations 40
- US citizen in Canada — filing US taxes from abroad
- Green card holder living in Canada
- US citizen living in India
- Accidental American who never filed US taxes
- Dual citizen with two passports, two returns
- US person married to a non-resident spouse
- US person with a foreign business
- Moving to Canada — a newcomer's first return and benefit claims
- Leaving Canada — departure (emigration) tax
- Returning to Canada after years abroad
- Deemed resident vs factual resident
- Split-year (part-year) residency in Canada
- Keeping a home in Canada while abroad
- Non-resident rental income from Canadian property
- Foreign seller: capital gains and the clearance certificate
- Non-resident receiving a Canadian pension
- Non-resident with Canadian employment income
- Non-resident with Canadian dividends or interest
- Non-resident student — full-time study deductions
- Canadian working in the US — taxes on a TN, H-1B or L-1
- Canadian snowbird — the substantial presence test
- Canadian with US rental property — rental income for foreigners
- Canadian selling US property — capital gains on the sale (FIRPTA)
- Canadian with a US brokerage account
- Canadian with foreign inheritance
- Canadian receiving a foreign gift
- Canadian with an offshore account
- NRI Indian return — do you need to declare foreign assets?
- Working remotely from abroad — the tax implications
- Retiring abroad from Canada
- Retiring to Canada from abroad
- Foreign income subject to self-employment tax
- Digital nomad with no fixed residence
- NRI selling property in India
- NRI with rental income in India
- RNOR status — the two-year window
- Returning to India after years abroad
- Indian resident with foreign assets (Schedule FA)
- Repatriating money out of India
- US person with a TFSA or RESP — the reporting
Business situations 37
- Local resident director services in Canada
- Local resident director services in the US
- Local resident director services in India
- Canadian company expanding to the US — LLCs and global taxes
- Canadian subsidiary — cross-border compliance red flags
- Indian company setting up in Canada
- Indian company setting up in the US
- Canadian company opening in India
- Branch or subsidiary — which and why
- Setting up a US LLC as a Canadian
- Why a Canadian should rarely own an LLC
- Selling into the US without a US entity
- Registering for a US EIN & state nexus
- Hiring a contractor abroad — global payroll tax compliance
- Hiring an employee in another country
- Paying a non-resident for work done in Canada
- Paying royalties or licence fees abroad — withholding
- Paying dividends to a foreign parent
- Paying interest on a shareholder loan abroad
- Employer of record — the tax risk
- Intercompany management fees and transfer pricing
- Intercompany loans & thin capitalisation
- Related-party goods purchases — transfer pricing
- Cost-sharing between group companies
- IP moved between countries
- Independent agent and permanent establishment — international tax
- Foreign affiliate structure review
- Controlled foreign corporation rules — international tax
- Repatriating profits to Canada
- Holding company across borders
- Cross-border M&A tax due diligence
- Group restructuring or migration
- Pillar Two readiness assessment
- Corporate emigration from Canada
- Winding up a foreign subsidiary
- Foreign-owned Canadian company — filings
- Foreign-owned US company — filings
Treaties & withholding 30
- How to avoid double taxation
- Canada–US treaty explained
- Canada–India DTAA explained
- US–India treaty explained
- Canada–UK, UAE and Australia treaties
- Treaty residency tie-breaker (Article IV)
- Business profits and permanent establishment — Articles V and VII
- Dividends, interest and royalties — the treaty articles
- Pensions and annuities — the treaty article
- Employment income — the treaty article
- Students and trainees — the treaty article
- Artistes and sportspersons — the treaty article
- Limitation on benefits — the treaty test
- MLI & the principal-purpose test
- Certificate of residency — Canada, US, India
- Part XIII withholding review
- Regulation 105 waiver
- Regulation 102 waiver
- US 30 percent withholding and treaty rates
- Section 195 — TDS under a DTAA on Indian payments
- Lower or nil TDS certificate under section 197
- Withholding refund & recovery claims
- Competent authority / MAP request
- Advance rulings — India
- Treaty shopping & beneficial ownership
- Tie-breaking dual residency in practice
- Treaty relief for students & researchers
- Treaty relief on RRSP / 401(k) / IRA
- Social security totalization agreements — Canada and the US
- Which treaty wins when three countries apply
Catch-up & disputes 26
- IRS streamlined foreign offshore
- IRS streamlined domestic offshore
- Delinquent FBAR submission
- Delinquent information return procedures
- Quiet disclosure — why not to
- IRS voluntary disclosure practice
- Reasonable cause statements — penalty relief
- First-time penalty abatement
- CRA Voluntary Disclosures Program — offshore and unreported income
- Late T1135 — penalty relief
- Late T1134 — penalty relief
- Taxpayer relief — penalties & interest
- Filing 10 years of missed returns
- CRA foreign income audit
- CRA net worth audit
- CRA residency determination review
- IRS notice & CP letter response
- IRS audit of a foreign-income return
- Notice of objection (Canada)
- Tax Court of Canada appeals
- IRS appeals & the Taxpayer Advocate
- Indian scrutiny assessment (s.143(2))
- Indian reassessment notices (s.148)
- Appeal to CIT(A) — Form 35
- Second opinion on a filed return
- Amending a filed return — all three countries
Transfer pricing 30
- Do I need transfer pricing documentation?
- s.247 contemporaneous documentation (Canada)
- US s.482 documentation
- Indian TP documentation & Form 3CEB
- Master file
- Local file
- Country-by-country report
- Benchmarking study
- Functional & risk analysis
- Choosing a method — CUP
- Resale price & cost plus methods
- TNMM in practice
- Profit split method
- Intercompany agreements
- Management fee study
- Royalty rate study
- Intercompany loan pricing
- Guarantee fee pricing
- Cash pooling arrangements
- Cost-sharing arrangements
- Intangibles & DEMPE analysis
- Business restructuring & exit charges
- Safe harbour rules (India)
- Advance pricing arrangement — Canada
- APA — India
- TP audit defence file
- TP adjustments & secondary adjustments
- Corresponding adjustment via MAP
- Customs value vs transfer price
- TP for small and mid-size groups
Estates & trusts 22
- US estate tax exposure for Canadians
- US estate tax for non-resident aliens
- Canada–US estate tax treaty relief
- Cross-border wills
- Deemed disposition on death
- Terminal return & clearance certificate
- Estate administration across borders
- Graduated rate estates
- Non-resident trusts (s.94)
- Canadian beneficiary of a foreign trust
- Foreign beneficiary of a Canadian trust
- US grantor trust rules for Canadians
- Reporting a foreign trust (3520 / 3520-A)
- T1141 & T1142 trust reporting
- Inheriting property abroad
- Inheriting property in India
- Gifting across borders
- US gift tax for non-residents
- Life insurance across borders
- Alter ego & joint partner trusts
- Family business succession across borders
- Post-mortem planning & pipeline
Payroll & mobility 18
- Payroll for a foreign employee in Canada
- Payroll for a Canadian employee abroad
- US payroll for a Canadian company
- State payroll & nexus for remote staff
- Shadow payroll
- Tax equalisation & protection policies
- Assignment letters & secondments
- Short-term business visitors
- 183-day rules in practice
- Social security & totalization certificates
- CPP/EI vs FICA for cross-border staff
- Stock options across borders
- RSUs across borders
- Employee vs contractor — both countries
- Personal services business risk
- Relocation benefits & taxability
- Remote work policy — tax exposure
- Global mobility calendar & day tracking
Advisory: sales tax, GST/HST and VAT 15
- GST/HST registration for foreign businesses
- Simplified vs normal GST/HST registration
- Digital services & the marketplace rules
- US sales tax nexus for foreign sellers
- Economic nexus thresholds by state
- Marketplace facilitator rules
- Importing into Canada — GST & duty
- Importing into the US — duty & MPF
- EU VAT for Canadian sellers
- UK VAT registration
- Indian GST for foreign suppliers
- OIDAR services in India
- Customs valuation vs transfer price
- Drop-shipping tax exposure
- Recovering foreign VAT
Advisory: structures, funding and holding companies 13
- Entity selection across borders
- Hybrid entities & mismatches
- Debt vs equity funding
- Surplus & FAPI computations
- Foreign affiliate reorganisations
- Repatriation planning
- Exit strategy for founders
- IP holding & substance
- Substance requirements in practice
- Economic substance in the Gulf
- GIFT City & IFSC structures
- Second opinion on an existing structure
- Board & governance for foreign entities
Advisory: crypto and digital assets 12
- Crypto held on foreign exchanges
- Reporting crypto on T1135
- Crypto and the FBAR question
- Crypto trading vs investing
- Staking & yield income
- NFTs across borders
- Mining income & PE risk
- Crypto on emigration from Canada
- Crypto tax in India
- Moving crypto to a low-tax country
- Lost or stolen crypto claims
- Crypto for corporations
Advisory: arriving, leaving and giving up status 11
- Pre-immigration tax planning
- Trusts before becoming a resident
- Step-up in cost base on arrival
- Tax on permanent residency
- Tax when citizenship is granted
- Investor & start-up visa tax
- Study permit holders
- Work permit holders
- Expatriation tax (US s.877A)
- Covered expatriate testing
- Giving up a green card
Advisory: planning, calendars and risk reviews 5
Advisory: everything else 4
India desk 36
- Am I an NRI? — the 182 / 60+365 day tests
- Leaving India — becoming an NRI
- TDS when buying property from an NRI (s.195)
- Lower or nil TDS certificate for NRIs (Form 13, s.197)
- Repatriating sale proceeds out of India
- NRE, NRO and FCNR accounts — how each is taxed
- Interest on NRO deposits — withholding and refunds
- Capital gains on Indian shares and mutual funds for NRIs
- Indian ESOPs held after leaving India
- EPF, PPF and gratuity when you leave India
- Indian pension received abroad
- Inheriting property or money in India
- Gifting money to family in India
- DTAA relief — India and Canada
- DTAA relief — India and the United States
- Foreign tax credit in India (Form 67)
- Tax residency certificate and Form 10F
- Schedule FA — reporting foreign assets in an Indian return
- Black Money Act exposure for Indian residents
- Liberalised Remittance Scheme and TCS on remittances
- FEMA compliance for NRIs
- PAN and Aadhaar for non-residents
- Filing an Indian return from Canada or the US
- Advance tax and self-assessment for NRIs
- Scrutiny and reassessment notices for NRIs
- GIFT City and IFSC for NRIs and funds
- Crypto tax in India for non-residents
- Indian company paying a foreign consultant
- Foreign company with an Indian subsidiary — filings
- Place of effective management (POEM) risk
- Equalisation levy on digital services
- NRI joint accounts and clubbing
- Indian mutual fund TDS for NRIs
- Selling agricultural land in India as an NRI
- NRI home loan interest deduction
- Power of attorney for Indian tax matters
India business 20
- Setting up in India — branch, LO, project office or subsidiary
- Permanent establishment in India — service PE and secondments
- Royalty and fees for technical services — withholding
- Dividend repatriation from India
- Share buyback and capital reduction tax
- Transfer pricing in India — s.92 and Form 3CEB
- Safe harbour rules for Indian TP
- Advance pricing agreements in India
- GAAR — general anti-avoidance rules
- MAT and AMT for foreign-owned companies
- SEZ, GIFT City and tax holidays
- Startup tax exemptions and angel tax
- ESOP taxation for Indian employees of foreign parents
- FDI routes, FC-GPR and FC-TRS compliance
- Outbound investment (ODI) from India
- Indian payroll for a foreign employer
- Liaison office reporting and closure
- Indian GST registration for foreign suppliers
- Secondment agreements and reimbursement
- Indian withholding on software payments
India DTAA 8
Specialist services 47
- BEPS Compliance & Country-by-Country Reporting
- Canada–U.S. Cross-Border Tax for Global Clients
- Cross-Border Corporate Tax Advisor for Global Clients
- Cross-Border Estate & Inheritance Tax for Global Clients
- Cross-Border Retirement Tax Planning for Global Clients
- Departure Tax & Emigration Planning for Cross-Border & Global
- Digital Nomad & Remote Worker Tax for Cross-Border & Global
- Double Taxation (DTAA) Relief for Cross-Border & Global Clients
- Dual Citizenship & Expatriate Tax for Cross-Border & Global
- Expat Tax Services for Cross-Border & Global Clients
- FAPI & Controlled Foreign Affiliate Planning
- FBAR & FinCEN 114 Reporting for Cross-Border & Global Clients
- Foreign Tax Credit Optimization for Cross-Border & Global Clients
- Global Payroll & Employee Mobility for Cross-Border & Global
- Global Tax Consulting — Canada, U.S., Europe & Asia
- International Investments & Global Tax Strategies
- International Real Estate Tax for Cross-Border & Global Clients
- International Tax Accountant for Cross-Border & Global Clients
- International Tax Advice & Advisory for Cross-Border & Global
- International Tax Planning for Cross-Border & Global Clients
- International Tax Preparation & Compliance
- International Tax Structuring for Cross-Border & Global Clients
- International Trust Taxation for Cross-Border & Global Clients
- IRS Streamlined Filing Compliance for Cross-Border & Global
- Local Director & Officer Services — USA
- Newcomer & Immigrant Tax Planning for Cross-Border & Global
- Non-Resident Tax (Canada) for Cross-Border & Global Clients
- NR4 / NR6 Non-Resident Withholding for Cross-Border & Global
- Permanent Establishment Advisory for Cross-Border & Global Clients
- PFIC Analysis & Reporting (Form 8621)
- Regulation 102 / 105 Waivers for Cross-Border & Global Clients
- Resident Director Services
- Resident Director Services
- RRSP, 401(k) & IRA Cross-Border Planning for Global Clients
- Section 216 Non-Resident Rental Returns
- Section 217 Pension Elections for Cross-Border & Global Clients
- T1134 Foreign Affiliate Reporting for Cross-Border & Global
- T1135 Foreign Asset Reporting for Cross-Border & Global Clients
- Tax Treaty Planning & Relief for Cross-Border & Global Clients
- Transfer Pricing Documentation & Planning
- U.S. Citizens Living in Canada for Cross-Border & Global Clients
- U.S. Corporate Tax (1120, 1120-F & 5472)
- U.S. Personal Tax Returns (1040 & 1040-NR)
- U.S. Real Estate Tax & FIRPTA for Cross-Border & Global Clients
- U.S. Tax Advisor (Toronto) for Cross-Border & Global Clients
- U.S. Trust & Estate Tax for Cross-Border & Global Clients
- Withholding Tax Planning & Recovery for Cross-Border & Global
- A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
- Consultations scheduled to your working day rather than ours.
- Nothing is filed until you have read it.
Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
Questions readers ask before they pick a page
The fee is fixed and agreed in writing before any work begins, priced from the documents you send rather than estimated afterwards, and it does not move once accepted. You see the finished work and approve it before anything is filed.
A named adviser reviews every return and every information filing before it goes out, and the statutory pages on this site carry the name of the person who reviewed them and the date they did it. You approve the finished work yourself as the last step.
Send what you have — a return, a notice, a set of statements, in whatever state it is in — through the secure portal after the first call, and you get a written fixed fee back. Or call the 24-hour helpline on +1 (416) 619-0068 and we will tell you what is needed.
By situation and by form family rather than by a single flat list — individual situations, business and corporate matters, treaties, catch-up work, transfer pricing, estates, payroll and advisory each have their own section, so you can start from whichever description matches your own facts.
Start from the situations section, which is written in the reader's own words rather than in form numbers or legal terms, or call the helpline and describe what is actually happening — most situations map cleanly onto one of the existing categories once the facts are laid out.
Why clients bring cross-border and international tax services to us
The order of filing is planned, not improvised
Which return goes first decides whether relief can be claimed at all. That sequence is worked out before anything is submitted.
Late and missed years are ordinary work
An unfiled history is not a reason to wait longer. We assess what is still open and what relief the delay attracts before the first return goes in.
Residence is tested, not assumed
Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.
The reporting penalties get named early
The heaviest exposure on a cross-border file is usually a disclosure form, not the tax. We identify which ones apply before a deadline turns into a penalty.


How the work runs — quote first, then the work
- Step 1: Share your documents – A secure upload link arrives after the first call — send files in any state.
- Step 2: A written fixed fee – The quote is fixed from what you send; it does not move once accepted.
- Step 3: Preparation, both sides at once – The returns are drafted together, reconciled line against line.
- Step 4: Approve, then file – Nothing is filed until you have seen it and approved it.
Quoted up front, in writing.
Contact Us 24-hour helpline +1 (416) 619-0068Recommended by clients on both sides of the border
18,000+ clients across 4 global offices, fees fixed in writing before the work starts. The case write-ups are published in full, so the outcomes are checkable rather than claimed.
- One written number before work starts. The bill repeats the quote exactly; if the job grows, it is re-priced in writing instead of quietly extended.
- Offices in India, the USA, Canada and the UAE and a secure portal for the paperwork — nothing has to be posted or dropped off.
- A 5.0-out-of-5 Google rating, on an open profile, readable before you ever pick up the phone.
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Keep reading, sideways
Every link below is a full page of its own — the same depth as this one, for its own subject.
Services these clients use most
Who we help
The corridors we work every week
Cross-border situations we are engaged for
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 runsA TFSA That Costs More Than It Saves
Canadian tax-free accounts are not tax-free to a US person, and some of them carry a reporting form of their own. The file is a review of what is held, what each account triggers on the US side, and whether the account is worth keeping once the reporting is priced in.
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



