Fixed fees agreed before work starts – 18,000+ clients served
At Legal Quotient Consultants, we manage all your fapi & controlled foreign affiliate planning requirements, from compliance to strategic planning. Our expert team ensures compliance, maximizes deductions, and optimizes your financial strategies so you can focus on growing your business. Reasonably priced FAPI & Controlled Foreign Affiliate Planning with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.
Fixed-Fee · Trusted · Accurate · Quick · Easy · Economical
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Stay compliant and optimize your financial processes with our specialized fapi & controlled foreign affiliate planning services.
| Service | Includes | Fee | |
|---|---|---|---|
| Individual Cross-Border Tax | T1 + treaty coordination · Foreign income · Credits | FROM- $349 | Explore More |
| U.S. Tax Returns | 1040 / 1040-NR · State returns · FBAR | FROM- $449 | Explore More |
| Corporate International Tax | T2 + foreign affiliate · T1134 · Repatriation | FROM- $999 | Explore More |
| Transfer Pricing Documentation | Local file · Benchmarking · s.247 compliance | FROM- $2,500 | Explore More |
| Cross-Border Estate & Trust | Terminal returns · U.S. estate tax · Clearance | FROM- $799 | Explore More |
Canada's foreign accrual property income rules tax a Canadian shareholder each year on its share of the passive income — interest, rent, royalties, certain capital gains and income from an investment business — earned by a controlled foreign affiliate, whether or not the affiliate paid a dividend. Active business income earned by the affiliate is not accrued and comes home through the surplus system, which decides whether a dividend is exempt, taxable with a deduction, or fully taxable, based on the country the affiliate is in and the nature of the earnings. The United States and other countries run parallel controlled-foreign-company regimes with their own definitions.
Planning is about the character of the income and the structure of the group: whether an activity is an active business or an investment business, whether income from a related party is recharacterised, whether the affiliate is in a treaty country so its active earnings build exempt surplus, and how debt and services within the group affect the characterisation. The T1134 information return is where the analysis is reported, and it has to agree with what the affiliate actually did.
Our foreign subsidiary reinvests all its profits. Is anything taxable in Canada? Its active business income is not accrued, but any passive income it earns is taxed to the Canadian shareholder each year whether or not it is distributed; the annual computation decides how much.
What is exempt surplus? Active business earnings of an affiliate resident and carrying on business in a country Canada has a treaty or exchange agreement with; a dividend paid from it comes to a Canadian corporate shareholder without further Canadian tax.
FAPI & Controlled Foreign Affiliate Planning: Legal Quotient Consultants provides fapi & controlled foreign affiliate planning for corporations operating, invoicing or owning subsidiaries across borders — planned and filed by cross-border specialists, with fixed fees agreed up front and every position explained before anything is submitted.
Send your documents securely through our portal or by email.
We prepare your fapi & controlled foreign affiliate planning return and every supporting schedule.
You review each figure and approve before anything is filed.
We file with the CRA and send you the confirmation of receipt.
| Factor | Legal Quotient Consultants | Typical Firm |
|---|---|---|
| Pricing model | Fixed, flat fee | Hourly / unpredictable |
| Experience | 15+ years, 18,000+ clients | Varies |
| Helpline | 24 hours a day, +1 (416) 619-0068 | Office hours only |
| Where we work | Our offices in India, the USA, Canada and the UAE | One office only |
| CRA audit support | Included | Billed extra |
Passive income in a controlled foreign affiliate can be taxed in Canada as it accrues; active-business characterization and surplus planning keep the system workable.
Related-party cross-border pricing must satisfy the arm's-length principle; Canada's contemporaneous documentation rules (s.247) expose undocumented positions to transfer pricing penalties once adjustments pass the statutory threshold. Engagements are quoted as a fixed fee for a defined scope, and reviews of prior-year filings are included where earlier positions affect the current one.
Covers: The related-party transaction return, reconciled to the corporate return and to the non-resident slips so the three tell one consistent story.
What moves it up: Inconsistency between the three filings. Where the return, the slips and the schedules disagree, resolving the difference is the engagement rather than the filing.
See this fee pageCovers: The foreign affiliate return with a full set of schedules per affiliate, restated onto the basis the return requires rather than the basis the local accounts use.
What moves it up: The number of affiliates and the tiers between them. Work scales with entity count, not with revenue, and lower-tier affiliates each need their own reporting.
See this fee pageCovers: The Canadian corporate return with the cross-border schedules that travel with it — foreign income, payments to non-residents, and the foreign affiliate flags.
What moves it up: The number of related-party transactions. A single management fee is manageable; a dozen intercompany flows brings the related-party return and transfer-pricing support with it.
See this fee pageProviding tailored fapi & controlled foreign affiliate planning services to ensure compliance and maximize deductions.
Our cross-border tax accountants protect your business with complete federal and provincial tax compliance.
A dedicated team that handles your financials quickly and accurately, at a fixed fee agreed in writing before any work starts.
Dedicated preparation processes built around the countries each client files in.
Documents, questions and signatures in one portal, whichever country you are filing from.
Customized packages designed to grow as your business operations expand.
Start with a free, no-obligation consultation to review your business’s financial, tax filing and compliance needs and outline our affordable solutions.
Receive a comprehensive checklist and securely provide the required financial records and documents.
Our tax accountant and accounting experts carefully prepare your filings, identify all applicable deductions and credits, and conduct thorough reviews.
We file your documents electronically with the Canada Revenue Agency (CRA) on time and provide post-filing support.
Quoted up front, in writing.
Contact UsCA (India), CA (Malaysia)
CA (India)
FCA (India)
CPA (Canada), CPA (USA), CA (India)
CPA (Canada), CA (India)
FAPI & Controlled Foreign Affiliate Planning starts at a fixed fee quoted before any work begins. The quote is locked at the outset and does not change mid-engagement, and you review the deliverable with us before it is filed. Compare every plan on our transparent pricing page.
At minimum: prior-year returns and notices of assessment, your bank and credit-card statements for the fiscal period, payroll records if you have employees, and GST/HST filings. We send a checklist tailored to your situation after the first call to our 24-hour helpline.
Most engagements are completed within 3 to 5 business days once your documents are complete. Catch-up work covering multiple years takes longer, and we tell you the realistic timeline before you commit rather than after.
We respond on your behalf at no extra charge for any return we prepared. Every figure we file is supported by documentation retained in your file, which is what turns a CRA review from a crisis into correspondence. See how our CRA audit support works.
Yes. The late-filing penalty is 5% of the balance owing plus 1% of that balance for each full month the return is late, to a maximum of 12 months (CRA, 2025 tax year). Interest is what compounds, daily, on top. We prioritise catch-up work and, where eligible, file under the CRA's Voluntary Disclosures Program to reduce penalties.
Yes. We work with clients wherever they live, from our offices in India, the USA, Canada and the UAE, and your location does not change the price or the service. Browse our coverage by country and region to find yours.
We work across construction, healthcare, e-commerce, professional services, restaurants, real estate, transportation, technology and non-profits, each with its own deduction profile and the points tax authorities scrutinise. See all industries we serve.
Software applies the rules you told it about. It does not ask whether a treaty caps the withholding on that payment, whether the foreign credit was claimed in the right country, whether an information return was due on an account that earned nothing, or whether your related-party pricing is documented. Those are the questions that move the number on a cross-border file.
Our fapi & controlled foreign affiliate planning services include complete filing, compliance management, and strategic advice customized to Canadian tax laws.
You can start by calling our 24-hour helpline on +1 (416) 619-0068 or sending the form. We will review your files, provide a fixed quote, and start working immediately.
This is the classic hybrid mismatch. The United States generally treats a single-member LLC as transparent and taxes the member on the profit as it arises. Canada treats the LLC as a corporation and taxes the member on distributions. So the two countries tax different amounts in different years, and the foreign tax credit — which needs the same income taxed by both in the same year — often cannot bridge it. The treaty relief for hybrids is narrow. See why a Canadian should rarely own an LLC.
A branch keeps one taxpayer: results consolidate at home, losses are usable sooner, and the exposure is that the branch is a permanent establishment whose profit the host country taxes, sometimes with a branch tax on repatriation. A subsidiary is a separate taxpayer with limited liability and local rates, at the cost of withholding on dividends home and transfer pricing on everything between them. The deciding facts are usually expected losses, liability and exit plans. See branch against subsidiary.
Still have questions? View our FAQ page or contact us.
A Canadian resident held all the shares of a consulting company incorporated abroad and had treated its profits as untaxed in Canada until distributed. The company had contracts, a leased office and staff in the foreign country, but also held a large cash balance earning interest. We reviewed the operating records, split the income between the trading activity and the investment return, and documented why one fell outside the accrual rule and the other did not. The engagement produced a written characterisation of each income stream, supported by contracts and payroll records, and a corrected position for the year under review.
A client had inherited an interest in a foreign company whose only asset was a let apartment building. Nobody had considered the Canadian treatment because the company paid its own tax abroad and distributed nothing. We examined how the property was run, concluded that the rent was passive in the shareholder's hands, and quantified the annual inclusion from the company's own accounts. The work consisted of restating the foreign statements under Canadian concepts, calculating the relief for foreign tax the company had paid, and filing the outstanding years. The engagement produced a documented accrual position and a set of filings brought up to date.
A business owner discovered that information returns for a group of overseas subsidiaries had never been filed, although the Canadian corporate returns had. We reconstructed the ownership chain, identified which companies met the affiliate test in each year and which did not, and obtained financial statements for the periods concerned. The work included preparing the returns in date order so the group's changing structure was visible, and drafting a covering explanation of how the omission arose. The engagement produced a complete filed record for the affected years and a schedule the client now uses to check the position annually.
A family group held companies in three countries through intermediate holding structures, and nobody could say which entities were controlled from Canada. We built the share register from the constitutional documents rather than from the organisation chart, traced holdings through each tier, and applied the control test to the Canadian residents involved together with their related parties. The work consisted of documenting each link with evidence and identifying the entities whose income was attributable. The engagement produced an ownership map, a written control conclusion for every company in the group, and a shorter reporting list than the client expected.
A shareholder intended to bring accumulated profits home and wanted to know the Canadian cost before committing. We reviewed how the subsidiary's earnings had arisen over its life, separated profits from active operations from investment returns, and identified amounts already taxed in the shareholder's hands under the accrual rule. The work included checking the foreign withholding position on a distribution and the records needed to support it. The engagement produced a written repatriation note setting out the order in which distributions should be made and the documents to be retained before the payment was authorised.
A client moved to Canada holding shares in an operating company in their home country. From the date of arrival the company came within the Canadian rules, and its accounting year straddled that date. We apportioned the company's income across the period, characterised each stream, and established the opening values that would matter on any later sale of the shares. The work consisted of obtaining audited statements from the foreign accountants, reconciling them to Canadian concepts, and setting out the reporting obligations that began on arrival. The engagement produced a first year filing position and a note for the client's records.
Owning a company abroad triggers an information return separate from the corporate return, with its own penalty. The work is the surplus and income computations behind it, which also determine how a future dividend is taxed on the way home.
Read how this one runsThe estate article can extend a proportionate credit where the two systems would otherwise both tax the same asset. Claiming it requires a valuation and a disclosure the estate may not expect to make.
Read how this one runsAll case studies — every published engagement in one place.
Strategy and compliance for income, assets and families spread across borders.
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.
Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.
