26 pages. Behind on filings, or facing a notice. Both are routine engagements here. 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.
Catch-up filings, disclosures and disputes
Behind on filings, or facing a notice. Both are routine engagements here.
- 15+Years of the founder's cross-border experience
- 18,000+Clients served across our offices in India, the USA, Canada and the UAE
- 5.0Google rating
- 4Global offices — India, USA, Canada & UAE
Secure a fixed quote
Begin with the papers you already have. The engagement is priced from them, in writing, before the work.
24-hour helpline: +1 (416) 619-006826 pages in this section. Behind on filings, or facing a notice. Both are routine engagements here.
← All cross-border and international tax services
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.
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
- 18,000+ clients served across 4 global offices: India, the USA, Canada and the UAE.
- Every statutory figure in your file is verified for your own year at source.
- Consultations scheduled to your working day rather than ours.
Reviewed for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.
Common questions about this section
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.
Not necessarily — several catch-up routes exist specifically for taxpayers who come forward before being contacted, and the applicable route usually depends on how the non-compliance happened rather than on the number of years missed.
It is worth reviewing your specific facts first, since the available catch-up routes are chosen based on the reasons behind the gap and on which years are genuinely still open — filing before that review risks choosing the wrong route and losing access to a better one.
The difference a dedicated cross-border team makes
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.
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.
The fee is fixed before we start
Quoted from your documents and agreed in writing. The number you accept is the number you pay.
We say early if it is not our work
If a file needs something this practice does not do, you hear that at the start rather than after a bill.


A fixed quote first, in writing
- 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) 619-0068Recommended by clients on both sides of the border
The claims on this site are deliberately few: fixed fees agreed in writing before work starts, 15+ years of cross-border experience, 18,000+ clients served across 4 global offices, and a helpline that answers 24 hours a day. Anything that cannot be evidenced does not go on a page.
- Priced in writing before anything is prepared. The invoice never exceeds the quote — extra scope gets its own quote before it gets done.
- Meet us in Kensington, Toronto or Delhi, or send everything through the secure portal — the process is the same either way.
- A 5.0-out-of-5 Google rating, on an open profile, readable before you ever pick up the phone.
We list coverage only where the article can be linked. What we say publicly, and where · Credentials and memberships · Read the reviews
The rest of this practice
Every link below is a full page of its own — the same depth as this one, for its own subject.
Core services for this situation
Clients who arrive with this exact page
Where our clients live and work
Files that look like this one
Dormant years rebuilt from bank statements before any filing
A client who had lived abroad and come back had kept nothing. We drew the slip history from the tax authority's account, then worked through bank and brokerage statements to rebuild the years the slips did not cover, including the disposals that had never been reported. Each return was prepared in sequence so carry-forward balances moved correctly from one year into the next. The engagement produced a complete filed set, a written reconciliation showing how every line was derived, and a schedule of the balances as finally assessed.
Notional assessment replaced by the return it stood in for
A year had been assessed on the tax authority's own initiative from third-party slips, with no deductions and no cost base against a share disposal, and the balance had been growing ever since. We prepared the real return for that year, filed it with the supporting schedules and the broker records, and asked for the notional assessment to be displaced. The work produced a reassessment built on actual figures, a documented record of what had been substantiated, and a consistent basis for the years that followed it.
Disclosure prepared before the first letter arrived
A taxpayer with foreign accounts wanted to come forward but had no idea what those accounts had earned. We reconstructed the income year by year from institution statements, converted it, and drafted the application with a narrative setting out how the omission arose and what had been done to correct it. The engagement produced a filed disclosure, the corrected returns that sat behind it, and a documented position the client can point to if the file is examined later.
Objection filed to keep a disputed reassessment open
A reassessment denied expenses the client could in fact support, and the window to challenge it was closing. We filed a formal objection setting out the grounds and identifying the evidence, which kept the year live while the underlying records were assembled properly. The work produced a written submission to the appeals officer built on invoices, contracts and bank entries rather than on argument, and a file the client could hand to anyone who asked what the position was and why.
Back years completed for a company that had stopped trading
Operations had ceased and nobody had filed since, but the corporation still existed and the filing obligation had not stopped with the trading. We reconstructed each open year from the bank record and the last set of accounts, filed the outstanding corporate returns in order, and reconciled the shareholder balances that had drifted. The engagement produced a filed set for every open year, a closing balance sheet the directors could act on, and the paperwork needed to end the obligation cleanly.
Relief request supported after a long illness
Returns had gone unfiled through a period of hospital treatment and recovery, and the penalties had accumulated on top of the tax. We filed the outstanding years first, because a request for relief is difficult to assess while the underlying returns are still missing, then made a written request supported by medical documentation and a dated timeline tying the gap to the illness. The engagement produced the filed years, a documented relief request on the file, and a payment arrangement for the balance that remained.
A Disclosure Where the Facts Were Not Innocent
Where non-compliance was not inadvertent, the certification-based routes are unavailable and a different practice applies, with its own protections and its own price. Establishing which side of that line the facts fall on is done before contact is made.
Read how this one runsA Penalty Argued on the Facts Rather Than the Form
Reasonable cause is a documented story with dates, not an assertion of good intent. The engagement assembles what the client actually knew and when, and puts the sequence in writing alongside the filings it explains.
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
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Performance income is taxed where earned — Regulation 105 in Canada, withholding agreements in the U.S. — with special treaty articles overriding the usual rules.
Performance income is taxed where the performance happens, and the deduction is usually taken at source on the gross fee before expenses. Recovering the difference is a filing exercise in the other country, and it only works if the tour, the residency and the withholding certificates were documented while the work was being done.
- 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



