Affordable Form T400A — notice of objection

Form T400A — who files it, when it is due, what late filing costs, and what we charge to prepare it. Canada (CRA). Ask us about affordable T400A: call the 24-hour helpline on +1 (416) 619-0068, or request a written fixed quote today.

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  • 15+ years of cross-border experience
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  • Fixed fee agreed before work starts
In 60 words

Form T400A is an objection, appeal or adjustment: The formal objection that disputes an assessment or reassessment and starts the appeals process. Taxpayers who disagree with a Canadian assessment, including residency determinations and foreign-reporting penalties.

Who this applies to

Taxpayers who disagree with a Canadian assessment, including residency determinations and foreign-reporting penalties.

One question decides the rest of the file. The deadline is the whole ball game: file within it and the assessment is under objection, miss it and the only routes left are an extension application or relief. Objecting also changes collection, which matters when the amount is large.

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

What t400a notice of objection costs here

What decides the fee on a notice of objection is the ground in dispute and the state of the file: a computational error backed by documents already in hand is one piece of work, while a residency determination or a foreign-reporting penalty means assembling the facts and the argument from scratch. Quoted in writing before drafting begins.

CRA voluntary disclosure package — fixed-fee price

From $349

fixed, quoted before work starts

The disclosure application with the corrected filings, a documented chronology of how the failure arose, and representation through to the CRA's decision.
See the full fee page

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

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

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

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

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

Payroll & mobility setup

From $999

fixed, quoted before work starts

The employer side of mobility — where to register, what to withhold, and what to report once someone works across a border.
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

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

What the reporting test actually looks at

What decides whether Form T400A applies
What is disputedEvidence relied on
The obligationThe formal objection that disputes an assessment or reassessment and starts the appeals process.
Who it bindsTaxpayers who disagree with a Canadian assessment, including residency determinations and foreign-reporting penalties.
Jurisdiction and authorityCanada — CRA
Category of filingObjection, appeal or adjustment

When it is due

Dispute deadlines run from the date of the notice or order, not from the filing season, and they are the hardest deadlines in tax to extend. Inside the period the assessment is under dispute; outside it, the routes narrow to an extension application or a relief request. Where an extension is available we tell you what it does and does not cover, because the two are frequently confused.

What late or missed filing costs

Missing the deadline does not create a penalty — it converts a disputable assessment into a final one. That is a larger consequence than any penalty on the file. Relief exists for most of these situations, and it is conditional on how the correction is made. That is the part worth getting right.

A worked example

The arithmetic is more persuasive than the description, so:

How an information-return exposure compounds

A filer who owed no tax at all, but missed an information return for 6 years with 1 form due each year. Assume a per-form penalty of US$6,000 for the illustration.

How an information-return exposure compounds
ItemAmount
Years unfiled6
Forms due per year1
Assumed penalty per formUS$6,000
Exposure before any reliefUS$36,000
Tax actually owed on the incomeUS$0

US$36,000 of exposure against nil tax. That asymmetry is why the disclosure routes exist and why the sequence of filings matters more than the arithmetic — filed in the right order under the right route, the penalty position can be very different from this. We run this on your actual numbers before advising anything, because the conclusion can invert with a modest change in inputs.

Example figures throughout, selected to make the rule visible, with rates and thresholds assumed for the demonstration. Your actual filing uses figures confirmed with the issuing authority for your tax year.

How we prepare and file it, and what it costs

The fee for Form T400A 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 dividends, interest and royalties — the treaty articles for comparable engagements.

The four steps

  1. 1Diarise the deadline from the notice and confirm what is actually in dispute
  2. 2Assemble the evidence for the position being taken
  3. 3File the objection or appeal with the grounds properly framed
  4. 4Manage the correspondence, and preserve the record for any further stage
  • Nothing is filed until you have read it.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.
  • 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.

Read and approved 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.

Canada tax forms — what this page covers

Read this page for Canada tax forms. It works through T400A from the beginning — whether it applies to you at all, what has to be filed if it does, and what the engagement costs, priced up front.

The deadline is the whole ball game: file within it and the assessment is under objection, miss it and the only routes left are an extension application or relief.

How the engagement runs, phase by phase

  1. Hand over the paperwork in any state

    Sorting it is our job. Send what exists and we identify what is missing from it.

  2. Priced before a single form is opened

    The fee comes from the documents, agreed in writing, and stays where it was agreed.

  3. One position across every return

    The same facts, filed consistently on each side, so nothing contradicts anything else.

  4. Filed after you have read it

    The completed work reaches you before it reaches an authority.

How t400a notice of objection is handled here

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

Key terms behind this page, defined

Grossing up
Restating a net-of-tax amount to its pre-tax equivalent, needed whenever a foreign payment arrived after withholding and the credit is claimed on the gross figure.
FCNR account
A foreign-currency deposit for non-residents, which removes rupee exchange risk and has its own tax and repatriation treatment.
Reassessment notice
A notice reopening a closed year. The first response is about the validity of the reopening, not the merits.
Updated return
India's route to voluntarily correct or file late within a statutory window, on payment of additional tax and with limits on what it may do.
t400a notice of objection: The practitioner's note

The deadline is the whole ball game: file within it and the assessment is under objection, miss it and the only routes left are an extension application or relief.

The engagement terms hold no matter what the analysis finds — fee and scope agreed in writing up front, a named reviewer on the output, your approval before the finished work is filed.

Fixed fees around t400a notice of objection

Where the objection window has already closed, the route changes to an application for an extension of time or to a taxpayer relief request, and that is separate work with its own fee. The number of taxation years under assessment matters as well, since each reassessment is objected to on its own footing.

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

Individual tax filing

$349fixed, before work starts

Covers: 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 this fee page

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.

The quote comes from your documents

Nothing is priced from a phone call. We read what you have first, then the fee is set — so the scope and the number are agreed on the same evidence.

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.

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

The team reviewing a file together at a desk

How the engagement runs, phase by phase

Step 1

Initial call

A call to the 24-hour helpline to find out whether this is a filing or a project

Step 2

Scope and fee

A fixed fee for a written scope — re-quoted if the scope changes, never invoiced silently

Step 3

Preparation and review

Preparation against the evidence, with the positions documented as we go

Step 4

Filing and payment

Your approval, then the filing — in that order

The team at work in the open-plan office

The engagement, start to finish

  • Step 1: Tell us the dates and we will tell you the position – Arrival, departure, the years in between — the residence question turns on those before anything else.
  • Step 2: Fixed fee, defined scope, in writing – Both agreed before work starts, so the engagement cannot grow into a larger bill.
  • Step 3: Prepared together, not passed between firms – You are not the go-between for two sets of advisers working from two sets of assumptions.
  • Step 4: Reviewed, approved, filed – A named practitioner checks it, you approve it, and then it goes.

Quoted up front, in writing.

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

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Where our clients live and work

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Israel tax for expats — country guide Everything on Israel tax for expats, at the same depth as this page.
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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

Objection filed against a determination of continuing Canadian residence

A client who had left Canada was reassessed on the footing that residence had never ceased, which brought worldwide income back into the Canadian return for the years after the move. We rebuilt the departure chronologically from the documents the family still held: the disposal of the home, the closing and opening of accounts, the movement of household goods, and the ties retained. The objection identified each reassessed year, set out the date residence was said to end, and attached the record supporting it. The file produced a documented residency position, filed within the objection deadline, that the appeals review was then conducted on.

Case study 2

Extension application prepared after the objection deadline had passed

The assessment had been sitting in a drawer and the objection period had run out before anyone looked at it. We checked the assessment date and confirmed the position rather than filing an objection that would simply be refused, then prepared an application to extend the time to object, explaining why the delay occurred and what was done once it was noticed. The substantive grounds were drafted at the same time so the objection was ready to stand if the extension was granted. The engagement produced a completed extension application with the objection attached, and a written note of the alternative relief route if it failed.

Case study 3

Objection to a foreign reporting penalty assessed after late filing

Forms had been filed voluntarily and late, and a penalty followed. The client's instinct was to write a letter asking for leniency. We separated the two questions: whether the penalty was properly assessed on the facts, which belongs in an objection, and whether it should be waived, which belongs in a relief request. The objection was drafted on the first question, tied to what was filed and when, with the correspondence trail attached in date order. The work produced an objection filed within the deadline and a relief request held in reserve, so neither route was lost by pursuing the other.

Case study 4

Objections filed across several years on a single disputed item

The same item had been treated the same way in more than one return, and only the earliest year had been reassessed. Waiting to see how that year turned out risked the later years closing to objection in the meantime. We set out the assessment dates year by year, drafted the grounds once, and filed an objection for each year that was open, each identifying its own assessment. The engagement produced a set of objections filed within their deadlines and a single written statement of the disputed position, so every year in dispute rests on the same documented argument.

Case study 5

Collection consequences settled before a large objection was filed

The amount assessed was large enough that the client's first question was not about the merits but about what could be collected while the dispute ran. We set out how objecting changes the collection position for a taxpayer in their circumstances, which parts of the balance that treatment covers, and that interest continues on whatever is finally owing. With that on paper the client decided deliberately how to deal with the balance instead of by default. The objection was then drafted and filed on the merits, and the engagement produced both the objection and a written note of the collection position it was filed under.

Case study 6

Reassessment of a treaty based position disputed on the documents

A credit claimed under a treaty had been disallowed on reassessment, and the correspondence had gone back and forth in general terms without the underlying records ever being produced. We treated the objection as an evidence exercise: what income arose, where it arose, what tax was paid on it abroad, and how each entry in the return tied to a document. The grounds were written to address the basis of the disallowance rather than restate the claim. The work produced an objection filed in time, supported by an indexed document set, which gave the appeals review something to decide on.

Case study 7

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 8

Unreported Foreign Income Disclosed Before the CRA Asked

A voluntary disclosure has to be genuinely voluntary — once a letter arrives, the route usually closes. The engagement establishes whether the programme is still available, prepares the years, and puts the relief request in with the filing rather than after it.

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 T400A — questions we are asked

Do I file Form T400A even if no tax is owed?

Objection, appeal or adjustment obligations of this kind are generally required on the facts rather than on the tax result, so a nil position does not remove one. Taxpayers who disagree with a Canadian assessment, including residency determinations and foreign-reporting penalties.

What happens if I have missed Form T400A 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 T400A the same as the other reports I already file?

No. The formal objection that disputes an assessment or reassessment and starts the appeals process. Satisfying a different obligation, even one covering the same accounts or entity, does nothing for this one.

How do I dispute a CRA reassessment I disagree with?

You file a notice of objection. Form T400A is the formal document that puts an assessment or reassessment in dispute and starts the appeals process, and it has to be filed within the objection deadline for that assessment. The objection should set out the facts you rely on, the reasons you say the assessment is wrong, and the documents supporting each point. Vague disagreement gets a vague answer. Where the dispute turns on residency, on the source of an amount, or on a penalty, the evidence attached at this stage is usually the evidence the appeals review is decided on, so it is worth assembling properly before filing rather than promising it later.

What happens if I miss the notice of objection deadline?

The objection route closes on its own terms and two narrower doors remain. The first is an application to extend the time to object, which asks for a late objection to be accepted and carries conditions of its own. The second is a request for relief, which does not overturn the assessment but can address penalties and interest. Neither is as good as an objection filed in time, because an in-time objection puts the assessment itself in dispute as of right. If the deadline has passed, say so at the outset rather than filing as though it has not. An extension application is different work, and it starts with explaining the delay.

Does filing an objection stop the CRA collecting the amount?

Objecting changes the collection position, which is one of the practical reasons to file rather than argue informally. The change is not the same for every type of taxpayer or every type of amount, so the answer for a large corporate assessment is not the answer for an individual, and some amounts remain collectible while the objection is outstanding. Interest also keeps running on whatever is ultimately owing. Where the balance is large enough that collection matters, settle that question at the same time as the objection is drafted, and decide deliberately whether to pay, to post security, or to let the balance stand.

Can I object to the CRA deciding I stayed resident?

Yes. A residency determination reaches you as an assessment or reassessment, and an assessment can be objected to. These files are decided on facts rather than argument: where your home was, where your family lived, where your belongings and accounts sat, what ties were kept and what were closed, and when each of those changed. The objection is the place to put that record in order, dated and documented, rather than described in general terms. Because the finding usually affects more than one year and can carry reporting consequences alongside the tax, work out at the start which years are open and which are being decided by this objection.

Do I need a lawyer to file a notice of objection?

No. An objection is a filing, not a court proceeding, and it can be prepared and filed by the taxpayer or by a representative you authorise. What it needs is not advocacy but precision: the assessment identified correctly, the years identified correctly, the facts stated in a way that matches the documents behind them, and each ground tied to the part of the assessment it disputes. If the objection is not resolved at that stage the file can go further, and a well-built objection is what the later steps are built on. We prepare objections on a fixed fee agreed in writing before any work starts.

Can I object to a penalty for late foreign reporting?

A penalty assessed against you comes in an assessment, and that assessment can be objected to. The objection has to engage the basis of the penalty rather than the fairness of it, which usually means addressing what was filed, when, what was known at the time, and what was done once the omission came to light. There is a separate relief route aimed at penalties and interest, and the two are not alternatives to be chosen casually. An objection preserves the dispute over whether the penalty is properly assessed at all; relief asks for it to be waived or cancelled. Which fits depends on the facts and on where the deadline stands.

Do Canada and the United States share tax information?

Yes, through more than one channel. The treaty has an exchange-of-information article that supports both routine and on-request exchange. Separately, an intergovernmental agreement has Canadian financial institutions identify US-reportable accounts and report them to the CRA, which passes them to the IRS, with the reverse flow for Canadian residents. Most other country pairs use the Common Reporting Standard for the same purpose. See FATCA reporting.

How does cross-border tax planning work?

It starts with facts rather than structures: which countries have a claim on you, what each one taxes, and where the two overlap. From there the decisions are about order and timing — which country taxes first, where relief is claimed, and whether a filing or a certificate has to be in place before money moves rather than after. Most of the value is in the sequencing, because relief claimed late is usually relief recovered slowly. See international tax planning.

24-hour helpline: +1 (416) 619-0068

Form T400A, quoted before we start

We scope it on a call, quote it in writing, and you see the result before anything is filed.

  • Fixed fees agreed before work starts
  • Your existing accountant keeps the domestic file
  • 24-hour helpline, +1 (416) 619-0068

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