Value-priced Form NR74 — determination of residency on entering

Form NR74 — who files it, when it is due, what late filing costs, and what we charge to prepare it. Canada (CRA). Value-priced NR74 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.

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Whatever documents you hold are enough to begin: we read them and put a fixed price in writing first.

24-hour helpline: +1 (416) 619-0068
  • 15+ years of cross-border experience
  • Google rating 5.0 out of 5
  • 18,000+ clients served
In 60 words

Form NR74 is a residency or status filing: The request for a determination of residency status on entering Canada. Newcomers, returning residents and people with ties in more than one country who need their Canadian start date settled.

Whether this is your situation

Newcomers, returning residents and people with ties in more than one country who need their Canadian start date settled.

Here is the part that decides your answer. Arrival date drives the deemed acquisition of cost base, the first-year proration of credits and when foreign-asset reporting begins — which makes a contested arrival date expensive in both directions.

Two of the firm’s advisers and the team in the open-plan office

NR74 determination of residency entering — priced before we start

What drives the fee on a determination of residency on entering Canada is the arrival date and everything that hangs from it: holdings that take a deemed cost on the day residency begins, part-year credits, and foreign reporting that starts from the same point. Ties held in more than one country lengthen the review.

Newcomer first return — fixed-fee price

From $349

fixed, quoted before work starts

The first Canadian return as a part-year return, with credits prorated correctly and the arrival-day cost base documented for everything brought in.
See the full fee page

Individual tax filing

From $349

fixed, quoted before work starts

A personal filing built from your own documents — employment, investment and rental income across borders, with the treaty position set out.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

Arrival and departure years priced as one engagement, with the part-year residence position and the assets deemed disposed of on exit.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

Disclosure of assets and interests held abroad, built once from a single asset list and filed on every side that asks for it.
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

Corporate cross-border filing

From $999

fixed, quoted before work starts

Corporate returns with foreign income, related-party reporting and cross-border structures, for companies of any size.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

Employer registration and withholding for staff on assignment, arranged before the first pay run rather than corrected after it.
See the fee schedule

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Intercompany pricing documented before it is questioned — the functional analysis, the benchmarking and the files that support it.
See the fee schedule

All published fees on one page — one page, every published fee, nothing quoted as a vague bracket.

What the reporting test actually looks at

What decides whether Form NR74 applies
Test appliedEvidence that decides it
The obligationThe request for a determination of residency status on entering Canada.
Who it bindsNewcomers, returning residents and people with ties in more than one country who need their Canadian start date settled.
Jurisdiction and authorityCanada — CRA
Category of filingResidency or status filing

When it is due

Status filings are generally made with the return for the year of the arrival, departure or presence in question. Some are optional and can be made at any time; the ones that accompany a return follow the return's date. The date is confirmed for your year at the start of the engagement, not assumed from last year's.

What late or missed filing costs

The exposure is not usually a penalty. It is the default status: days that should have been excluded are counted, a residency position that should have been documented is not, and a whole year of worldwide income comes into a tax base it should never have entered. We quantify the exposure in writing before recommending a route, so the decision is made on numbers rather than on anxiety.

The arithmetic, worked through

This is what the rule produces when you put figures through it.

A deemed disposition on the day residency ends

A portfolio bought for C$321,000 is worth C$548,910 on the departure day. Nothing is sold. Assume half the gain enters income and assume a 40% marginal rate on it.

A deemed disposition on the day residency ends
ItemAmount
Cost of the propertyC$321,000
Value on the departure dayC$548,910
Accrued gain treated as realisedC$227,910
Amount assumed to enter incomeC$113,955
Tax at an assumed 40%C$45,582

C$45,582 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. The shape of that result holds; the size of it depends entirely on your own numbers and dates.

Treat these numbers as a worked example rather than advice — they exist to make the mechanics visible, and the rates and thresholds are assumed for the illustration. For a real filing, we verify each figure with the authority that publishes it, for your year.

How we prepare and file it, and what it costs

The fee for Form NR74 is fixed against a written scope and agreed before we start. It is not billed by the hour and it does not move after the fact. See the repatriating money out of India for comparable engagements.

What working with us looks like

  1. 1Reconstruct the presence record and the ties on both sides
  2. 2Determine the status under domestic rules and, where relevant, the treaty
  3. 3File the statement or schedule that documents it
  4. 4Keep the evidence pack, because this is the position most often reviewed later
  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
  • Documents move through one secure portal, and you can meet us in person at any of our offices.
  • Authorisation with each authority, so we see the assessments and slips directly rather than asking you for them.

Describe the situation in your own words; translating it into forms is our job.

Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.

Where corporate tax payment CRA comes into this file

Most readers of this page are looking for corporate tax payment CRA. What follows sets out how it works for NR74: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.

Arrival date drives the deemed acquisition of cost base, the first-year proration of credits and when foreign-asset reporting begins — which makes a contested arrival date expensive in both directions.

The four phases of the work

  1. Send what you already have

    Slips, statements, prior returns — in any order. We list what is still needed after reading them.

  2. A fee agreed in writing

    Quoted from those documents, before the work starts, and it does not move once you accept it.

  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.

  4. You approve before it is filed

    The finished return comes to you first. Nothing is submitted on your behalf unseen.

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

Four terms worth pinning down

Resale price method
A method testing the gross margin earned by a reseller, sensitive to consistent classification between cost of sales and operating expense.
Specified foreign financial asset
The class of asset reportable on the US FATCA statement: foreign accounts, foreign-issued securities, interests in foreign entities and certain foreign contracts.
Schedule FSI
The Indian schedule reporting foreign-source income and the tax paid on it, country by country, from which the foreign tax credit claim is built.
Effectively connected income
US-source income connected with a US trade or business, taxed on a net basis at graduated rates on a return rather than by flat gross withholding.
NR74 determination of residency entering: The practitioner's note

Arrival date drives the deemed acquisition of cost base, the first-year proration of credits and when foreign-asset reporting begins — which makes a contested arrival date expensive in both directions.

Whichever way the facts cut, you keep the same footing: a fee agreed in writing beforehand, a named practitioner reviewing the file, and nothing filed until the work is delivered and approved.

The published fees closest to NR74 determination of residency entering

A newcomer with one employment contract and a rented flat is a different engagement from a returning resident with continuing ties abroad and a portfolio to inventory as at the date of arrival. The second needs those holdings listed and valued before the request is drafted. Both prices are agreed in writing first.

Non-resident & departure filings

$349fixed, before work starts

Covers: 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 this fee page

Foreign asset & information reporting

$349fixed, before work starts

Covers: Accounts, property and company interests held outside the country of residence, reported on the schedules that carry penalties whether or not tax is owed.

See this fee page

Why choose Legal Quotient for NR74 determination of residency entering

18,000+ clients served

Individuals, expats and corporations across India, the USA, Canada and the UAE have filed with us — 15+ years of cross-border work.

The fee is fixed before we start

Quoted from your documents and agreed in writing. The number you accept is the number you pay.

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.

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.

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

How the engagement runs, phase by phase

Step 1

Establishing the facts

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

Step 2

Agreeing the fee

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

Step 3

Drafting and review

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

Step 4

Filing and follow-up

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

The team reviewing a file together at a desk

From first document to filed return

  • 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) 619-0068

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

Form 10FA / 10FB — TRC for Indian residents (India) The full guide to form 10fa / 10fb India, with the fee fixed before any work starts.
Form T2062C — section 116 notification Its own page: t2062c section 116 notification — mechanism, deadlines and published fees.
Form NR301 — treaty benefit declaration Everything on nr301 treaty benefit declaration, at the same depth as this page.
Form 8854 — expatriation statement, the US exit tax US exit tax — the guide, the FAQ and the fixed fee.
Form T2209 — federal foreign tax credit The full guide to T2209 federal foreign tax credit, with the fee fixed before any work starts.
Paying dividends to a foreign parent Its own page: paying dividends to a foreign parent — mechanism, deadlines and published fees.
Study permit holders Everything on study permit holders, at the same depth as this page.
Form 26AS — tax credit statement (India) Form 26as India — the guide, the FAQ and the fixed fee.
Business profits and permanent establishment — Articles V and VII The full guide to business profits permanent establishment article, with the fee fixed before any work starts.

Who we help

Tax for mining engineers & geologists The full guide to mining engineers & geologists tax, with the fee fixed before any work starts.
Professors & lecturers — what we charge Its own page: professors & lecturers what we charge — mechanism, deadlines and published fees.
Influencers & content creators — what you owe in each country Everything on influencers & content creators what you owe in each country, at the same depth as this page.
Amazon FBA sellers — your filing calendar Amazon fba sellers your filing calendar — the guide, the FAQ and the fixed fee.
Tax for defence contractors The full guide to defence contractors tax, with the fee fixed before any work starts.
Airline pilots — what you owe in each country Its own page: airline pilots what you owe in each country — mechanism, deadlines and published fees.
Law firms cross-border tax Everything on law firms cross border tax, at the same depth as this page.
Tax for diplomatic & consular staff Diplomatic & consular staff tax — the guide, the FAQ and the fixed fee.
Agriculture & agri-tech cross-border tax The full guide to agriculture & agri-tech cross border tax, with the fee fixed before any work starts.

Where our clients live and work

Barbados tax for expats — country guide The full guide to Barbados tax for expats, with the fee fixed before any work starts.
Moldova tax for expats — country guide Its own page: moldova tax for expats — mechanism, deadlines and published fees.
Hungary tax for expats — country guide Everything on hungary tax for expats, at the same depth as this page.
India–United Kingdom tax corridor India United Kingdom tax — the guide, the FAQ and the fixed fee.
Jordan tax for expats — country guide The full guide to jordan tax for expats, with the fee fixed before any work starts.
Canada–Philippines tax corridor Its own page: Canada Philippines tax — mechanism, deadlines and published fees.
Austria tax for expats — country guide Everything on Austria tax for expats, at the same depth as this page.
Georgia tax for expats — country guide Georgia tax for expats — the guide, the FAQ and the fixed fee.
Sri Lanka tax for expats — country guide The full guide to Sri Lanka tax for expats, with the fee fixed before any work starts.

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 tax case studies

Case study 1

First Canadian Return After Arriving Mid-Year

The arrival date splits the year and sets the cost base of what you brought with you. Getting that date and those values right is what determines whether a later sale is taxed on the whole gain or only on the part that accrued after landing.

Read how this one runs
Case study 2

Interest and Penalties Put to a Relief Application

Relief is discretionary and is decided on the circumstances that caused the delay, evidenced year by year. The application is built from the same chronology the filings rest on, so the two cannot contradict each other.

Read how this one runs
Case study 3

A Distribution From a Trust Set Up Abroad

A distribution can be capital in the trust's country and income here, and the reporting attaches to the beneficiary rather than the trustee. The work is characterising the payment before it is received where possible.

Read how this one runs
Case study 4

A Family Trust Abroad With Reporting on Both Sides

A trust settled in one country and a beneficiary living in another produces reporting for the trust, the settlor and the beneficiary, on different forms and different dates. The engagement maps who files what before anything is prepared.

Read how this one runs
Case study 5

A Residency Determination Review After Leaving the Country

Residence is decided on ties, not on a form, and the review asks for evidence of every one of them. The file assembles the ties that were severed and the ones that remained, and answers the questionnaire against the treaty rather than around it.

Read how this one runs
Case study 6

Accounts Reported Late When the Income Already Was

Where the income was on the return and only the account report was missed, a narrow route allows late filing with a reason attached. It is open only while no income is unreported and no examination has begun, which is why it is checked first.

Read how this one runs
Case study 7

A US LLC Owned by a Canadian, Taxed Twice by Design

The two countries classify an LLC differently, so the credit relief that ought to apply frequently does not. The engagement looks at whether the structure can be changed, and where it cannot, at how to make the credit work.

Read how this one runs
Case study 8

A Trust Abroad With a Canadian Connection

Contributions or beneficiaries in Canada can bring a foreign trust inside the Canadian net entirely. The analysis is who contributed what and when, because the answer decides whether the trust files here at all.

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

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
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • 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

Form NR74 — questions we are asked

Do I file Form NR74 even if no tax is owed?

Residency or status filing obligations of this kind are generally required on the facts rather than on the tax result, so a nil position does not remove one. Newcomers, returning residents and people with ties in more than one country who need their Canadian start date settled.

What happens if I have missed Form NR74 for several years?

Missed years are dealt with as a package rather than one at a time, because the route chosen for the first year affects the relief available for the rest. We map the years and the obligations before anything is filed.

Is Form NR74 the same as the other reports I already file?

No. The request for a determination of residency status on entering Canada. Satisfying a different obligation, even one covering the same accounts or entity, does nothing for this one.

How are non-residents taxed on Canadian rental income?

By default the payer or agent withholds a flat rate on the gross rent and remits it, with no deduction for mortgage interest, taxes or repairs. Electing under section 216 lets you file on the net rental result instead, which for most properties recovers a substantial part of what was withheld; an NR6 undertaking filed before the year starts lets the withholding itself be computed on net rather than gross. See the section 216 return.

How many days can I spend in a country before I become tax resident?

It depends on the country, and a day count is only ever the start. Many use a threshold in a tax year, some also look at averages across several years, and some have no day test at all and decide on where your home and life are. Two countries can both conclude you are resident, which is what the treaty tie-breaker exists to settle. Counting days without checking the tie-breaker is how people end up filing as resident nowhere. See the residency tie-breaker.

What is Part XIII withholding?

Canada's flat withholding on certain payments to non-residents — dividends, interest to related parties, rents, royalties, pension and annuity payments, management fees. The payer withholds and remits, and is liable if they do not, which is why they insist on documentation. A treaty can reduce the rate, but only where the recipient has given the payer the declaration establishing entitlement before payment. Where too much was withheld, a refund claim is the route, with its own time limit. See Part XIII withholding review.

A named reviewer on every filing

Let us take Form NR74 off your desk

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.

  • Offices in India, the USA, Canada and the UAE
  • 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