Affordable US s.482 documentation

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The US framework tests the arm's-length result, not the taxpayer's intention, and it allows the authority to adjust to the best method — so the file has to justify the method as well as the number. Affordable US s.482 documentation 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.

+1 (416) 619-0068 See fixed fees
  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
Google Rating 5.0Clutch Rating 5.0

Secure a fixed quote

Send what you have. We price the engagement from your own documents, in writing, before any work starts.

24-hour helpline: +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • 24-hour helpline: +1 (416) 619-0068
  • 15+ years of cross-border experience
The short answer

The US framework tests the arm's-length result, not the taxpayer's intention, and it allows the authority to adjust to the best method — so the file has to justify the method as well as the number. Documentation prepared by the return date supports the reasonableness of the method and the reliability of the comparables.

Who has to deal with this

  • A year-end adjustment was booked without documenting the basis
  • The benchmarking study on file is more than a couple of years old
  • Your group has any transaction with a related non-resident
  • Intercompany prices were set internally with no external support
  • A tax authority has asked whether documentation exists

Most people who need help with US s.482 documentation tick at least two of those. If you tick none, we would rather tell you that on a call than take an engagement you do not need.

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

What US s.482 documentation costs here

What sets the fee on a US arm's-length documentation file is the number of intercompany transactions covered and whether a benchmarking study has to be built from the ground up or only refreshed. Writing up why the alternative methods were rejected is the section that takes the work. The fee is agreed in writing first.

Transfer pricing — local file — fixed-fee price

From $2,500

fixed, quoted before work starts

The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.
See the full fee page

TP benchmarking study — fixed-fee price

From $2,500

fixed, quoted before work starts

A documented search: screening criteria, quantitative and qualitative filters, a manual rejection log with reasons, and the resulting range with the tested party's position in it.
See the full fee page

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Benchmarking and documentation for related-party dealings, prepared to the standard the reviewing authority applies.
See the fee schedule

Corporate cross-border filing

From $999

fixed, quoted before work starts

The corporate return and its cross-border schedules as one engagement, so the group files a consistent position everywhere.
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

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

Returns for people whose tax position did not stay in one country, including the years residence itself is in question.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

For anyone taxed by a country they do not live in — rent, pensions and investment income reaching across a border after the move.
See the fee schedule

All published fees on one page — all of it on a single page, so the number you compare is the number you pay.

The rule behind the paperwork

The US framework tests the arm's-length result, not the taxpayer's intention, and it allows the authority to adjust to the best method — so the file has to justify the method as well as the number.

Documentation prepared by the return date supports the reasonableness of the method and the reliability of the comparables. Best-method analysis means explaining why the alternatives were rejected, which is the section most files skip.

The practical reading of that is simple enough. Establish the position first, in writing; assemble the evidence that supports it; then prepare the filings in the order that lets the relief actually land. Doing those three in the other order is how the cost of US s.482 documentation multiplies.

Every statutory figure that reaches your file is checked against the authority that issues it, for the year in question, before anything is filed. Where we cannot verify a number for your year, the advice explains the mechanism instead and says so plainly, because an unverified threshold is a liability rather than a shortcut. See also local resident director services in India and trusts before becoming a resident.

What we actually file

  • Intercompany agreements that match the conduct
  • The information return that discloses related-party transactions
  • A defence file of the evidence behind the documentation
  • Adjustment and corresponding-adjustment computations
  • Advance pricing applications where certainty is worth buying

The arithmetic, worked through

Worked through with figures, the mechanism looks like this.

An operating margin against a tested range

A limited-risk entity with C$33,000,000 of revenue reporting a 4% operating margin. Assume a benchmarking study produced an interquartile range of 4% to 9%.

ItemAmount
RevenueC$33,000,000
Operating margin reported4%
Operating profit reportedC$1,320,000
Assumed tested range4% – 9%
Profit at the bottom of the rangeC$1,320,000
Potential adjustmentC$0

The reported margin sits inside the tested range, which is the outcome documentation is meant to demonstrate. Keep the study current: a range computed three years ago is not evidence about this year. That is an illustration of the mechanism, not a prediction about your file — the same computation on your figures is the first thing we do.

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.

From first call to filed

  1. 1A call to the 24-hour helpline to find out whether this is a filing or a project
  2. 2A fixed fee for a written scope — re-quoted if the scope changes, never invoiced silently
  3. 3Preparation against the evidence, with the positions documented as we go
  4. 4Your approval, then the filing — in that order

What it costs

The commercial part is deliberately boring. One fixed fee for a written scope, agreed up front in writing — which is what lets us tell you honestly when US s.482 documentation is smaller than you feared. Comparable engagements and their fixed fees are set out on the pricing pages.

  • A named reviewer signs off every statutory filing.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.
  • Fixed fees agreed before any work starts, so the number in the quote is the number on the invoice.

Where to go from here

Bring last year's returns and we will tell you what is missing. Send whatever you have — even an incomplete set. Most of the first hour of a US s.482 documentation engagement is working out which documents actually matter, and that is quicker with a partial pack than with none.

Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.

Transfer pricing tax, in practice

If you came here for transfer pricing tax, this is where it is dealt with. The subject is US s.482 documentation, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.

The US framework tests the arm's-length result, not the taxpayer's intention, and it allows the authority to adjust to the best method — so the file has to justify the method as well as the number.

How the engagement runs, phase by phase

  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.

How US s.482 documentation 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

Four terms worth pinning down

Virtual digital asset
India's statutory category for crypto and similar assets, taxed under a dedicated regime with a transaction-level deduction at source.
Newcomer
Someone who has become resident during the year. Property held on arrival is generally treated as acquired at that day's value, which is why arrival-value evidence is worth keeping.
Advance pricing arrangement
An agreement with one or both tax authorities fixing the transfer-pricing method for future years, and in some countries for past ones by rollback.
Master file
A transfer-pricing document describing the group as a whole — structure, intangibles, financing — filed locally in several countries at once.
US s.482 documentation: The practitioner's note

Documentation prepared by the return date supports the reasonableness of the method and the reliability of the comparables.

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 US s.482 documentation

Documentation that has to be ready by the return date prices differently from a file reconstructed after a year-end adjustment was already booked. The number of entities in the group, and how many of them sit outside the US, decides how much of the analysis has to be repeated. Each is quoted in writing before the work starts.

Corporate cross-border filing

$999fixed, before work starts

Covers: The corporate return and its cross-border schedules as one engagement, so the group files a consistent position everywhere.

See this fee page

Transfer pricing documentation

$2,500fixed, before work starts

Covers: Local file, master file and benchmarking for groups trading across borders, documented to the standard the authority expects.

See this fee page

Payroll & mobility setup

$999fixed, before work starts

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

See this fee page

Why clients bring US s.482 documentation to us

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.

4 global offices

Meet us in person in India, the USA, Canada and the UAE, or send everything through the secure portal — the same process either way.

One team, not two firms billing separately

You are not the go-between for two sets of advisers with two sets of assumptions. One engagement covers each country the file touches.

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 firm’s founder at his desk in the Delhi office

From first call to filed return

Step 1

Initial call

A first call to map the obligations across every country involved

Step 2

Scope and fee

A single fixed fee covering the whole set, agreed before we begin

Step 3

Preparation and review

Preparation in the order that makes the relief usable, with a reviewer's sign-off

Step 4

Filing and payment

You approve the finished work, and we file it

The team reviewing a file together at a desk

The engagement, start to finish

  • 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

More of the same work, from other angles

Every link below is a full page of its own — the same depth as this one, for its own subject.

The work we do for clients like this

Form 8865 — foreign partnership Everything on form 8865 foreign partnership, at the same depth as this page.
Social security totalization agreements — Canada and the US Social security totalization agreement Canada US — the guide, the FAQ and the fixed fee.
Employer of record — the tax risk The full guide to employer of record tax risk, with the fee fixed before any work starts.
DTAA relief — India and the United States Its own page: DTAA relief — India and the United States — mechanism, deadlines and published fees.
Foreign-owned US company — filings Everything on foreign-owned US company filings, at the same depth as this page.
Form ITR-4 (Sugam) — presumptive income (India) ITR-4 (sugam) India — the guide, the FAQ and the fixed fee.
Relocation benefits & taxability The full guide to relocation benefits & taxability, with the fee fixed before any work starts.
Form T3 non-resident beneficiary — reporting Its own page: t3 non-resident beneficiary reporting — mechanism, deadlines and published fees.
RSUs across borders Everything on rsus across borders, at the same depth as this page.

Who we help

Tax for influencers & content creators Everything on influencers & content creators tax, at the same depth as this page.
Professors & lecturers — what you owe in each country Professors & lecturers what you owe in each country — the guide, the FAQ and the fixed fee.
Manufacturers cross-border tax The full guide to manufacturers cross border tax, with the fee fixed before any work starts.
Airline pilots — relief you're probably missing Its own page: airline pilots relief you're probably missing — mechanism, deadlines and published fees.
IT contractors — what we charge Everything on it contractors what we charge, at the same depth as this page.
Professors & lecturers — what we charge Professors & lecturers what we charge — the guide, the FAQ and the fixed fee.
Software developers — relief you're probably missing The full guide to software developers relief you're probably missing, with the fee fixed before any work starts.
Crypto traders — your filing calendar Its own page: crypto traders your filing calendar — mechanism, deadlines and published fees.
Tax for options & futures traders Everything on options & futures traders tax, at the same depth as this page.

The corridors we work every week

Serbia tax for expats — country guide Everything on serbia tax for expats, at the same depth as this page.
India–Singapore tax corridor India Singapore tax — the guide, the FAQ and the fixed fee.
Canada–UAE tax corridor The full guide to Canada UAE tax, with the fee fixed before any work starts.
Romania tax for expats — country guide Its own page: romania tax for expats — mechanism, deadlines and published fees.
Ireland tax for expats — country guide Everything on Ireland tax for expats, at the same depth as this page.
Canada–United Kingdom tax corridor Canada United Kingdom tax — the guide, the FAQ and the fixed fee.
Jamaica tax for expats — country guide The full guide to Jamaica tax for expats, with the fee fixed before any work starts.
United States tax for expats — country guide Its own page: United States tax for expats — mechanism, deadlines and published fees.
Russia tax for expats — country guide Everything on Russia 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

Files that look like this one

Case study 1

A Margin Defended With a Benchmarking Set That Fits the Facts

A comparables set is only as good as the screening behind it, and a rejected set takes the margin with it. The study selects the tested party first, screens on function rather than on industry code, and records why each comparable survived.

Read how this one runs
Case study 2

An Adjustment in One Country and No Relief in the Other

A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.

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

A Non-Resident Estate Holding US Assets

US situs assets sit inside the US estate tax net regardless of where the owner lived, and the exemption available to a non-resident is not the resident one. The file establishes situs asset by asset before any relief is claimed.

Read how this one runs
Case study 5

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 6

Years Filed Quietly, and What That Cost

Posting missing returns without taking a view on the route gives up the certification-based protection and can itself be read as an indicator. The first task on these files is mapping which years remain eligible for which route.

Read how this one runs
Case study 7

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
Case study 8

A Clean History Used to Remove a First Penalty

An administrative waiver can remove a first failure where the filing and payment record supports it, and it is spent once used. Whether to claim it now or keep it for a heavier year is a judgement made with the whole file in view.

Read how this one runs

All case studies — every published engagement in one place.

Delivery, coverage and how we work

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

Where the work is delivered

More coverage detail

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

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

Treaty residency & tie-breaker
FATCA reporting (Form 8938)
Foreign tax credit (Form 1116)
Multi-country filing calendar
Real estate holding structures
International tax planning
Pre-immigration tax planning
Family office structures
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

Form 1040 from abroad
US state non-resident returns
FBAR (FinCEN 114) filing
Form 5472 — foreign-owned US corp
FIRPTA withholding (Form 8288)
US estate tax exposure
IRS streamlined foreign offshore
PFIC reporting (Form 8621)
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

Departure tax leaving Canada
T1161 properties on emigration
Residency planning
Step-up in cost base on arrival
Split-year residency
Employment income under a treaty
Social security totalization
Returning to Canada after years abroad
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

Section 216 rental return
NR4 & NR6 withholding
Section 217 pension return
Section 116 clearance certificate
Regulation 105 waiver
Non-resident employment income
Taxable Canadian property
Part XIII withholding review
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

s.247 contemporaneous documentation
Functional & risk analysis
Benchmarking study
Intercompany agreements
Country-by-country report
BEPS & Pillar Two
Permanent establishment risk
TP audit defence file
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

Cross-border wills
US estate tax for non-resident aliens
Terminal return & clearance certificate
Non-resident trusts (s.94)
T1141 & T1142 trust reporting
Inheriting property abroad
Graduated rate estates
Post-mortem planning & pipeline
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Entity selection across borders
Business profits & PE
Intercompany loans & thin cap
Paying dividends to a foreign parent
Global mobility & day tracking
Debt vs equity funding
Branch or subsidiary
Cross-border M&A due diligence
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

NRI residency day tests
NRE, NRO & FCNR accounts
TDS on property (s.195)
Lower or nil TDS certificate
Repatriating sale proceeds
Capital gains on Indian shares
India–Canada DTAA
ITR-2 for NRIs
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

T1135 foreign property
T1134 foreign affiliates
Departure tax
Newcomer's first return
Returning to Canada
Split-year residency
US citizens in Canada
Canada–US corridor
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

Expat tax in the UAE
Moving to the UAE
Moving back from the UAE
UAE property purchases
Retiring in the UAE
Canada–UAE corridor
India–UAE DTAA
US–UAE corridor
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

Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.

Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.

  • 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

  • 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

US s.482 documentation — questions we are asked

US s.482 documentation — where does doing it myself start to cost money?

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: documentation prepared by the return date supports the reasonableness of the method and the reliability of the comparables.

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.

What is OECD Pillar One?

The part of the international agreement that reallocates a share of taxing rights over the very largest and most profitable groups to the jurisdictions where their customers and users are, regardless of physical presence — plus a simplified approach to routine marketing and distribution returns. It is aimed at the digitalised economy problem that physical-presence rules could not reach, and its implementation is still moving, which is why we read the current instrument rather than the original blueprint. See BEPS and Pillar Two.

Do I need transfer pricing documentation?

If your company transacts with a related party in another country, in substance yes — the question is how much. Documentation is what shifts the burden: prepared before the filing deadline it evidences that your pricing was set on arm's length terms, and its absence is what turns a pricing adjustment into a penalty in several regimes. Volume of related-party dealings drives whether you need a local file, a master file, or a full benchmarking study. See do I need transfer pricing documentation.

What does a transfer pricing benchmarking study do?

It evidences that your related-party pricing sits within the range independent parties achieve. The work is comparison: identify companies or transactions genuinely similar in function, risk and assets, compute their margins, and show where your result falls against that range. Done before the filing deadline it supports the position; produced afterwards under audit it carries far less weight. See benchmarking study.

How long does it take?

It depends on the documents rather than on us. Once the pack is complete most individual filings turn around inside a fortnight; anything that needs a certificate or a foreign authority runs on that authority's timetable.

Is there a minimum engagement?

No, but there is a minimum that makes sense: below a certain scope the honest answer is often that you can handle it yourself, and we will say so.

Tax terms explained

FTC basketContemporaneous documentationReverse chargeBusiness visitorChapter 4 withholdingBusiness purpose testCompliance calendarCFCSection 216NRO accountNR6Trailing liabilityPersonal services businessNRE account Browse the full A–Z glossary

Related pages

Elsewhere in this section

All transfer pricingCash pooling arrangementsCost-sharing arrangementsProfit split methodTP adjustments & secondary adjustmentsGuarantee fee pricingTNMM in practice

Connected engagements

Cost-sharing between group companiesGiving up a green cardControlled foreign corporation rules — international taxSelling into the US without a US entityRegistering for a US EIN & state nexusCrypto held on foreign exchanges

Questions on this

Do I need US s.482 documentation?
No hourly billing, ever

Talk to us about US s.482 documentation

Tell us the situation and we quote in writing before any work starts. You approve the result before it is filed.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Re-quoted, never silently invoiced
  • Rated 5.0 out of 5 stars on Google
  • A named reviewer signs off every filing

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