Value-priced Covered expatriate testing

Most people who expatriate assume the net-worth test is the one that catches them. Ask us about value-priced covered expatriate testing: call the 24-hour helpline on +1 (416) 619-0068, or request a written fixed quote today.

  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 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) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • 18,000+ clients served
  • Fixed fee agreed before work starts
The short answer

Most people who expatriate assume the net-worth test is the one that catches them. The tests are applied at expatriation: average annual income tax over prior years, net worth on the date, and certification of compliance for the preceding years.

Whether this is your situation

  • You hold appreciated assets on the move date
  • You hold or are surrendering a green card or permanent residence
  • Trusts or companies are part of the picture
  • A start date has been agreed before the tax position was modelled
  • You have a window before residence begins and no plan for it

That list is deliberately concrete. If you recognise yourself in it, this page is the right starting point; if you do not, tell us and we will point you elsewhere without charging for it.

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

Fixed fees for covered expatriate testing, agreed up front

Covered expatriate testing is priced on the certification side more than the net-worth side: the years that have to be reviewed and, where returns are missing, brought current before anything can be certified. A clean filing history is a short exercise; unfiled years and trust or company interests are a longer one.

Corporate cross-border filing

From $999

fixed, quoted before work starts

Corporate compliance for a group that trades or holds assets in more than one country, prepared on both sides together.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

One engagement for a personal return that touches more than one country: the income, the assets held abroad and the relief claimed against them.
See the fee schedule

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Documentation for transactions between related companies: the method, the comparables and the file an authority asks to see.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

The information returns that carry the heaviest penalties — foreign accounts, foreign property, foreign affiliates — prepared from one asset list.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

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 the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

Voluntary disclosure handled as one piece of work, from the review of what is outstanding to the returns that close it.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

What an employer owes when an employee works in another country: the registrations, the withholding and the reporting that follow.
See the fee schedule

Estate & trust filing

From $799

fixed, quoted before work starts

For an estate holding property in more than one country, or a trust with beneficiaries who are taxed somewhere else.
See the fee schedule

All published fees on one page — each engagement priced as one number on one list, with nothing left as a range.

What the rule does, step by step

Most people who expatriate assume the net-worth test is the one that catches them. The certification test catches more, because it depends on filings made years earlier.

The tests are applied at expatriation: average annual income tax over prior years, net worth on the date, and certification of compliance for the preceding years. Failing to certify makes a person covered regardless of the other two.

That mechanism has a practical edge to it: it rewards preparation and punishes discovery. A filer who maps the obligation before the year ends is choosing between options; a filer who finds it afterwards is usually choosing between remedies.

Because a wrong number is worse than no number, every rate and threshold in your file is confirmed for your year at source. Where that confirmation is not available in time, the advice states how the rule works and what would need checking, rather than filling the gap with an estimate. See also pillar two readiness assessment and guarantee fee pricing.

What we actually file

  • Pre-arrival and pre-departure computations and elections
  • Arrival-value documentation that sets the cost base
  • The transition-year return with prorated credits
  • Expatriation statements and final-year filings where applicable
  • A written plan sequenced against the move date

What this looks like with numbers

Here is the rule doing its work on an actual set of amounts.

A deemed disposition on the day residency ends

A portfolio bought for C$321,000 is worth C$593,850 on the departure day. Nothing is sold. Assume half the gain enters income and assume a 31% marginal rate on it.

A deemed disposition on the day residency ends
ItemAmount
Cost of the propertyC$321,000
Value on the departure dayC$593,850
Accrued gain treated as realisedC$272,850
Amount assumed to enter incomeC$136,425
Tax at an assumed 31%C$42,292

C$42,292 becomes payable in a year with no sale and no cash. That is what makes the departure date a planning variable: losses realised before it, an election to defer payment against security, and defensible valuations for anything private all change this number. We run this on your actual numbers before advising anything, because the conclusion can invert with a modest change in inputs.

Illustrative figures, not a client engagement: the amounts are chosen to make the mechanism legible, and the rates and thresholds are assumptions stated for the example only. We confirm every one of them against the issuing authority for your own tax year before anything is filed.

How we handle it

  1. 1A first call to map the obligations across every country involved
  2. 2A single fixed fee covering the whole set, agreed before we begin
  3. 3Preparation in the order that makes the relief usable, with a reviewer's sign-off
  4. 4You approve the finished work, and we file it

Fees for this work

Pricing works the way it should: a defined scope and a fixed fee agreed in writing before anything starts. If the scope turns out to be larger than we thought, that is a conversation before the work, not a line on the bill. Comparable engagements and their fixed fees are set out on the pricing pages.

  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
  • A change of scope is re-quoted before the work, never added to the invoice after it.
  • A named reviewer signs off every statutory filing.

Where to go from here

Send us the facts and we will tell you what has to be filed and what it costs. Start with the dates. Arrival, departure, transaction, notice — whichever applies. Once those are fixed, the filing set and the fee follow quickly, and you will know both before committing to anything.

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.

Business tax advisory — what this page covers

Most readers of this page are looking for business tax advisory. What follows sets out how it works for covered expatriate testing: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.

Most people who expatriate assume the net-worth test is the one that catches them.

How the engagement runs, phase by phase

  1. Start with a conversation about the facts

    Dates, residence, where the income arose. Fifteen minutes is usually enough to know what applies.

  2. Scope and price, both written down

    You get the scope and the fixed fee together, so there is no question later about what was included.

  3. Prepared by one team, reviewed by a named practitioner

    The same people see both sides of the file, and the reviewer signs their name to it.

  4. Filed, then followed through

    Submission is not the end of the engagement — the queries that arrive afterwards are part of it.

The difference a dedicated cross-border team makes

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

The vocabulary this page leans on

Second opinion
A review of a filed position, which most often finds an unclaimed credit, a missed information return and an undisclosed treaty position.
Secure portal
An access-controlled channel for tax documents, used because tax records are the most sensitive papers most people own.
Foreign earned income exclusion
The US election that removes foreign earned income from taxable income, up to an annually adjusted cap, for a filer whose tax home is abroad and who meets one of two qualifying tests.
Compliance calendar
The mapped set of filings by entity and jurisdiction with an owner for each. Deadlines are missed because nobody owns the ones abroad, not because they are unknown.
covered expatriate testing: The practitioner's note

The tests are applied at expatriation: average annual income tax over prior years, net worth on the date, and certification of compliance for the preceding years.

Complexity changes the work, not the deal: the written fee and scope come first, a named practitioner signs off, and the filing follows your approval of the delivered file.

Fixed fees around covered expatriate testing

The other half of the work is building the net-worth statement as at the expatriation date, which is straightforward for listed holdings and slower where a private company, a pension or an interest in a trust has to be valued and evidenced. The scope is agreed in writing before we start.

Individual tax filing

$349fixed, before work starts

Covers: Individual returns where salary, investments or property sit outside the country of residence, prepared so relief is claimed once and in the right place.

See this fee page

Transfer pricing documentation

$2,500fixed, before work starts

Covers: Documentation for transactions between related companies: the method, the comparables and the file an authority asks to see.

See this fee page

Why clients bring covered expatriate testing to us

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.

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.

Cross-border is the whole practice

International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.

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.

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

How the engagement runs, phase by phase

Step 1

First conversation

A short call to work out what actually applies to you and what does not

Step 2

Written quote

A written quote against a defined scope, with nothing billed by the hour

Step 3

Preparation and sign-off

We prepare, a named reviewer checks it, and you see it before it goes

Step 4

Submission

You approve, we file, and only then do you pay

The team at work in the open-plan office

How the work runs — quote first, then the work

  • Step 1: Send what you already have – Slips, statements, prior returns — in any order. We list what is still needed after reading them.
  • Step 2: A fee agreed in writing – Quoted from those documents, before the work starts, and it does not move once you accept it.
  • Step 3: Each side drafted against the other – The returns are built together rather than in sequence, so relief is claimed once and in the right country.
  • Step 4: You approve before it is filed – The finished return comes to you first. Nothing is submitted on your behalf unseen.

Quoted up front, in writing.

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

Keep reading, sideways

Each of these carries its own guide, pricing pointers and FAQ.

Core services for this situation

Non-resident rental income from Canadian property Everything on non resident rental income tax Canada, at the same depth as this page.
Form 15G / 15H — no-deduction declarations (India) Form 15g / 15h India — the guide, the FAQ and the fixed fee.
Form T1248 — residency information schedule The full guide to t1248 residency information schedule, with the fee fixed before any work starts.
Non-resident with Canadian employment income Its own page: non-resident Canadian employment income — mechanism, deadlines and published fees.
Form 26Q — TDS on resident payments (India) Everything on form 26q India, at the same depth as this page.
MAT and AMT for foreign-owned companies Mat and amt for foreign-owned companies — the guide, the FAQ and the fixed fee.
Form 1042-S — recipient statement The full guide to form 1042-s recipient statement, with the fee fixed before any work starts.
US 30 percent withholding and treaty rates Its own page: US 30 percent withholding treaty rates — mechanism, deadlines and published fees.
Cross-border charity and donation relief Everything on cross-border charity and donation relief, at the same depth as this page.

Clients who arrive with this exact page

Tax for crypto traders Everything on crypto traders tax, at the same depth as this page.
IT contractors — relief you're probably missing It contractors relief you're probably missing — the guide, the FAQ and the fixed fee.
Mining & energy cross-border tax The full guide to mining & energy cross border tax, with the fee fixed before any work starts.
Day traders — your filing calendar Its own page: day traders your filing calendar — mechanism, deadlines and published fees.
Tax for software developers Everything on software developers tax, at the same depth as this page.
Management consultants — your filing calendar Management consultants your filing calendar — the guide, the FAQ and the fixed fee.
Construction & contracting — relief you're probably missing The full guide to construction & contracting relief you're probably missing, with the fee fixed before any work starts.
Amazon FBA sellers cross-border tax Its own page: amazon fba sellers cross border tax — mechanism, deadlines and published fees.
Tax for architects Everything on architects tax, at the same depth as this page.

The corridors we work every week

Indonesia tax for expats — country guide Everything on Indonesia tax for expats, at the same depth as this page.
Iceland tax for expats — country guide Iceland tax for expats — the guide, the FAQ and the fixed fee.
Trinidad & Tobago tax for expats — country guide The full guide to Trinidad & tobago tax for expats, with the fee fixed before any work starts.
Canada–Hong Kong tax corridor Its own page: Canada Hong Kong tax — mechanism, deadlines and published fees.
India–United Kingdom tax corridor Everything on India United Kingdom tax, at the same depth as this page.
Denmark tax for expats — country guide Denmark tax for expats — the guide, the FAQ and the fixed fee.
South Korea tax for expats — country guide The full guide to South Korea tax for expats, with the fee fixed before any work starts.
US–UAE tax corridor Its own page: US UAE tax — mechanism, deadlines and published fees.
Germany tax for expats — country guide Everything on Germany tax for expats, at the same depth as this page.

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

Indian Transfer Pricing Certification With a Hard Deadline

An Indian entity with international related-party transactions needs an accountant's report filed by a date of its own, ahead of the return. The work is reconciling the transactions to the books first, because the report is only as defensible as that reconciliation.

Read how this one runs
Case study 3

A US Filer Married to Someone Outside the System

Electing to treat a non-resident spouse as a US filer buys joint rates and brings that spouse's worldwide income and foreign accounts into the return. The election is easy to make and hard to revoke, so both positions are modelled first.

Read how this one runs
Case study 4

Expanding Abroad — Branch or Subsidiary, Decided on the Numbers

The choice sets the tax on profits, the treatment of early losses, and what it costs to take money home later. The file models all three across the first years rather than deciding on the incorporation cost alone.

Read how this one runs
Case study 5

A Secondment Whose Paperwork Decided the Tax

Who employs, who directs and who bears the cost are the facts a treaty article turns on, and an assignment letter is where they are recorded. Drafting it with the tax position in view prevents an argument later.

Read how this one runs
Case study 6

An Assignment Priced on an Equalisation Promise

A policy that leaves the assignee no better or worse off has to be computed, not just stated, and the hypothetical deduction runs alongside the real one. The engagement builds both and reconciles them at year end.

Read how this one runs
Case study 7

Indian Rent Collected While Resident Somewhere Else

Rent from Indian property is taxed in India and again where you live, with relief on one side only. The file gets the Indian deduction right first, then claims the credit on the home return against what was actually paid.

Read how this one runs
Case study 8

Never Filed a US Return — and Only Just Found Out

Born in the United States, left as an infant, and told by a bank that the returns were owed all along. The work is sequencing: establish which years are actually open, choose the catch-up route on the facts rather than filing quietly, and claim the exclusions and credits that were never taken.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

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

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

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

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

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

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

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

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

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

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

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

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

Working from anywhere doesn't mean taxed nowhere: residency defaults, employer payroll exposure and treaty relief decide where income actually lands.

Working from another country does not by itself end tax residence in the one you left, and it can start one where you are sitting. Day counts, ties, the employer's own exposure and the treaty tie-breaker all point at the same question, and the year you move is the year it has to be answered on paper.

  • 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

Covered expatriate testing — questions we are asked

Covered expatriate testing — do I need an adviser, or can I do it alone?

Some of it, yes — and we will say so on the call if that is the honest answer. The parts that are worth paying for are the ones where a missed election, a missed deadline or an unverified threshold costs more than the fee: the tests are applied at expatriation: average annual income tax over prior years, net worth on the date, and certification of compliance for the preceding years.

What if I have already filed and got it wrong?

That is a common starting point. We re-derive the position, identify whether an amendment or a disclosure route is the right vehicle, and tell you which one preserves the relief that is still available. The order matters more than the speed.

How long will it take?

It depends on the documents rather than on us. Once the pack is complete most filings turn around inside a fortnight; anything that needs a certificate from a tax authority runs on that authority's timetable, which we tell you at the start rather than at the end.

Is there a California exit tax?

A wealth-and-departure tax has been proposed in California more than once and has not been enacted. What does exist is enforcement of the ordinary rules, which reaches further than people expect: California taxes its residents on everything and taxes non-residents on California-source income, so trailing items from work done there remain taxable, and a change of residence is tested against a long list of factors rather than a moving date. See state residency and domicile.

Do I have to declare my dual citizenship?

A tax return does not generally ask you to declare which passports you hold; it asks about residence, and in the US case it applies to citizens by definition. What does ask is your bank. Account-opening self-certification under FATCA and the Common Reporting Standard asks which countries you are a tax resident or citizen of, and the answer is reported onward to the tax authority. So the practical answer is that the information arrives either way. See FATCA reporting.

How do I know whether I am a covered expatriate?

Three tests, and one is enough. Net worth of $2,000,000 or more on the day you expatriate. Average annual net income tax above an inflation-adjusted figure for the five preceding years — $206,000 for 2025. Or failure to certify on Form 8854 that you complied with all federal tax obligations for those five years. The third catches people the first two never would, which is why compliance history is the thing to fix before, not after. See covered expatriate testing.

Do you publish your fee schedule?

Yes — the pricing pages carry the published fees and what moves them. The exact number for your scope is confirmed in writing after the first call.

Can you talk to my lawyer or my banker?

Yes, with your authorisation. In cross-border files the bank and the lawyer frequently hold the document that decides the tax question, so bringing them in early saves a cycle.

Meet us in person at any of our offices

Covered expatriate testing, quoted before we start

One call to the 24-hour helpline is enough to tell you what has to be filed, what it costs, and whether you need us at all.

  • Fixed fees agreed before work starts
  • 24-hour helpline, +1 (416) 619-0068
  • 18,000+ clients served

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