Competitively priced Artistes and sportspersons — the treaty article

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Performers and athletes are the exception to the employment article: the country where the performance happens can tax the income from it regardless of how short the visit was. Competitively priced artistes and sportspersons 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
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Secure a fixed quote

Begin with the papers you already have. The engagement is priced from them, in writing, before the work.

24-hour helpline: +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • 15+ years of cross-border experience
  • Google rating 5.0 out of 5
The short answer

Performers and athletes are the exception to the employment article: the country where the performance happens can tax the income from it regardless of how short the visit was. Gross withholding is common, and it applies to appearance fees, prize money and often a share of endorsement income tied to the event.

Who this applies to

  • A third country has entered the picture and the two treaties disagree
  • Two countries are taxing the same income
  • A payer applied a statutory rate where a treaty rate was available
  • You need to prove residence to a foreign payer or authority
  • A treaty position needs to be claimed or disclosed on a return

Most people who need help with artistes and sportspersons — the treaty article 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.

The team reviewing a file together at a desk

Transparent, fixed pricing for artistes sportspersons treaty article

What decides the fee on an artiste or sportsperson engagement is the number of events and countries in the tour, and whether a withholding reduction has to be applied for before the promoter pays. A single appearance already contracted is a short piece of work; a season across several jurisdictions is not. Fixed fee agreed in writing first.

Reg 105 or 102 waiver application — fixed-fee price

From $999

fixed, quoted before work starts

The waiver application prepared and filed before the payment or the assignment, with the treaty basis or the income-and-expense computation that supports it.
See the full fee page

Dual filing — 1040 + T1 together — fixed-fee price

From $449

fixed, quoted before work starts

Both returns prepared as one engagement, in the order the credit requires, so relief lands where it is usable rather than being claimed twice in the wrong place.
See the full fee page

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

Individual tax filing

From $349

fixed, quoted before work starts

Individual returns where salary, investments or property sit outside the country of residence, prepared so relief is claimed once and in the right place.
See the fee schedule

Corporate cross-border filing

From $999

fixed, quoted before work starts

Returns for companies with foreign subsidiaries, foreign income or foreign shareholders, and the schedules each of those triggers.
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

Foreign asset & information reporting

From $349

fixed, quoted before work starts

The information returns that carry the heaviest penalties — foreign accounts, foreign property, foreign affiliates — prepared from one asset list.
See the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

For a filing history that stopped — the penalty position assessed first, then the years filed in the order that protects it.
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

Performers and athletes are the exception to the employment article: the country where the performance happens can tax the income from it regardless of how short the visit was.

Gross withholding is common, and it applies to appearance fees, prize money and often a share of endorsement income tied to the event. Reduction depends on a waiver or an expense-based application made before payment, and on how the contract allocates the fee.

This is why we start with a chronology rather than a form. Almost every position in this area is anchored to a date — of arrival, of departure, of a payment, of a transaction — and the evidence that supports it is either created around that date or reconstructed years later at several times the cost.

The standard here is simple: no figure without a source for your year. Anything that cannot meet it is written as a mechanism, so you can see exactly what the rule does even where the number has to be confirmed before filing. See also foreign seller: capital gains and the clearance certificate and India–Singapore tax corridor.

What we actually file

  • Correspondence with payers who applied the wrong rate
  • Confirmation of the treaty text actually in force for your year
  • Treaty-position disclosures on the return
  • Residency certificate applications and eligibility declarations
  • Waiver and reduced-withholding applications before payment

The numbers, end to end

Here is the rule doing its work on an actual set of amounts.

Credit relief on one stream of income

Take C$70,000 of income taxed in both countries. Assume the other country charged 21% on it and the home country would charge 41% on the same amount.

ItemAmount
Income taxed in both countriesC$70,000
Tax paid abroad (assumed 21%)C$14,700
Home tax on the same income (assumed 41%)C$28,700
Credit available (lesser of the two)C$14,700
Home tax still payableC$14,000

The credit absorbs C$14,700 and leaves C$14,000 payable at home, because the home rate on this income is the higher of the two. The balance is real cash and it is due on the home timetable, which is why instalments get raised in the first meeting. 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.

An illustration, not a client file. The sums are chosen for legibility and the thresholds are stated for the example alone — nothing reaches a filing until it has been confirmed at source for your own year.

From first call to filed

  1. 1We start with the chronology: dates, countries, and what has already been filed
  2. 2You get the scope and the fee in writing before we touch anything
  3. 3The work is prepared and reviewed by a named person, not a queue
  4. 4Nothing is filed until you have read it

The fixed fee

Fees for artistes and sportspersons — the treaty article are quoted as a fixed amount for a defined scope. There is no hourly meter and no surprise on the invoice: the number is agreed in writing before anything starts. Comparable engagements and their fixed fees are set out on the pricing pages.

  • Documents move through an access-controlled portal rather than email.
  • Fixed fees agreed before any work starts, so the number in the quote is the number on the invoice.
  • Every statutory figure in your file is verified for your own year at source.

How to get this moving

If you already have an adviser, we will tell you what they should be asking rather than replacing them. Send whatever you have — even an incomplete set. Most of the first hour of an artistes and sportspersons — the treaty article engagement is working out which documents actually matter, and that is quicker with a partial pack than with none.

Read and approved 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.

Where tax treaty article comes into this file

People reach this page searching for tax treaty article. It is covered here as it applies to artistes and sportspersons — who it applies to, what has to be filed, and what it costs, at a fixed fee agreed before the work starts.

Performers and athletes are the exception to the employment article: the country where the performance happens can tax the income from it regardless of how short the visit was.

From first contact to filed return

  1. Send the documents as they are

    No tidying required — forward what you have and we tell you what is missing.

  2. Get a fixed quote in writing

    Priced from your actual documents before any work begins, not estimated after.

  3. Both countries prepared together

    One team builds the filings against each other so the relief lands exactly once.

  4. Review, then file

    You approve the finished work before we file it.

How artistes sportspersons treaty article 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

The vocabulary this page leans on

FinCEN 114
The form number of the FBAR. It is filed electronically with FinCEN and is not attached to the tax return.
Schedule FA
The foreign asset schedule of the Indian return. There is no value threshold — one foreign account is enough to require disclosure.
Tax protection
A policy under which the employee is reimbursed only if the assignment leaves them worse off, keeping any windfall.
OIDAR
India's regime for online information and database access services, taxing a foreign supplier on sales to Indian consumers.
artistes sportspersons treaty article: The practitioner's note

Gross withholding is common, and it applies to appearance fees, prize money and often a share of endorsement income tied to the event.

However the file develops, three things stay fixed: a written scope and fee before work begins, a named practitioner reviewing the result, and your approval before anything is filed.

Fixed fees around artistes sportspersons treaty article

The contract itself is the other driver. Where one payment covers an appearance fee, prize money and endorsement work tied to the same event, the allocation has to be read and supported before anything is filed — and endorsement income shared between countries takes longer to settle than a straight performance fee.

Dual filing — 1040 + T1 together

$449fixed, before work starts

Covers: Both returns prepared as one engagement, in the order the credit requires, so relief lands where it is usable rather than being claimed twice in the wrong place.

What makes it bigger: Investment products. Local funds, tax-advantaged savings accounts and employer plans each need testing against the other system, and that is where a dual filing stops being two simple returns.

See this fee page

Reg 105 or 102 waiver application

$999fixed, before work starts

Covers: The waiver application prepared and filed before the payment or the assignment, with the treaty basis or the income-and-expense computation that supports it.

What makes it bigger: Lead time. Applied for early the waiver removes the withholding; applied for late it does nothing for the payment that has already been made.

See this fee page

Cross-border payroll setup

$999fixed, before work starts

Covers: Registrations, source deductions and reporting in the country of work, plus the social security certificate and the day-count discipline that supports the position.

What makes it bigger: The number of jurisdictions and whether any is sub-national. A single federal registration is quick; several states or provinces each bring their own filings.

See this fee page

Why choose Legal Quotient for artistes sportspersons treaty article

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.

Residence is tested, not assumed

Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.

A named reviewer on every file

Every page on this site and every file we deliver says which practitioner reviewed it — a person, not a team inbox.

You deal with the person who did the work

The practitioner who prepared and reviewed your file is the one who answers the question about it.

The team at work in the open-plan office

From first call to filed return

Step 1

First conversation

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

Step 2

Written quote

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

Step 3

Preparation and sign-off

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

Step 4

Submission

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

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

The engagement, start to finish

  • Step 1: Hand over the paperwork in any state – Sorting it is our job. Send what exists and we identify what is missing from it.
  • Step 2: Priced before a single form is opened – The fee comes from the documents, agreed in writing, and stays where it was agreed.
  • Step 3: One position across every return – The same facts, filed consistently on each side, so nothing contradicts anything else.
  • Step 4: Filed after you have read it – The completed work reaches you before it reaches an authority.

Quoted up front, in writing.

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

Keep reading, sideways

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

The work we do for clients like this

Form NR5 — reduced Part XIII withholding Its own page: nr5 reduced part xiii withholding — mechanism, deadlines and published fees.
Form ITR-3 — business or professional income (India) Everything on ITR-3 India, at the same depth as this page.
Indian ESOPs held after leaving India Indian ESOPs held after leaving India — the guide, the FAQ and the fixed fee.
Schedule TR — tax relief claimed (India) The full guide to schedule tr India, with the fee fixed before any work starts.
Form 26Q — TDS on resident payments (India) Its own page: form 26q India — mechanism, deadlines and published fees.
Stock options across borders Everything on stock options across borders, at the same depth as this page.
Form NR7-R — refund of Part XIII tax Nr7-r refund of part xiii tax — the guide, the FAQ and the fixed fee.
Intercompany loan pricing The full guide to intercompany loan pricing, with the fee fixed before any work starts.
Indian TP documentation & Form 3CEB Its own page: Indian tp documentation & form 3ceb — mechanism, deadlines and published fees.

Clients who arrive with this exact page

Cross-border real estate investors cross-border tax Its own page: cross-border real estate investors cross border tax — mechanism, deadlines and published fees.
Oil & gas rotational workers — relief you're probably missing Everything on oil & gas rotational workers relief you're probably missing, at the same depth as this page.
Oil & gas rotational workers — what we charge Oil & gas rotational workers what we charge — the guide, the FAQ and the fixed fee.
Tax for short-term rental hosts The full guide to short-term rental hosts tax, with the fee fixed before any work starts.
Touring musicians — your filing calendar Its own page: touring musicians your filing calendar — mechanism, deadlines and published fees.
Advisors & referral partners cross-border tax Everything on advisors & referral partners cross border tax, at the same depth as this page.
Management consultants — relief you're probably missing Management consultants relief you're probably missing — the guide, the FAQ and the fixed fee.
Tax for touring musicians The full guide to touring musicians tax, with the fee fixed before any work starts.
Investors & property owners cross-border tax Its own page: investors & property owners cross border tax — mechanism, deadlines and published fees.

The corridors we work every week

US–Australia tax corridor Its own page: US Australia tax — mechanism, deadlines and published fees.
Ireland tax for expats — country guide Everything on Ireland tax for expats, at the same depth as this page.
United States tax for expats — country guide United States tax for expats — the guide, the FAQ and the fixed fee.
Croatia tax for expats — country guide The full guide to croatia tax for expats, with the fee fixed before any work starts.
Hungary tax for expats — country guide Its own page: hungary tax for expats — mechanism, deadlines and published fees.
Uganda tax for expats — country guide Everything on uganda tax for expats, at the same depth as this page.
Greece tax for expats — country guide Greece tax for expats — the guide, the FAQ and the fixed fee.
Thailand tax for expats — country guide The full guide to Thailand tax for expats, with the fee fixed before any work starts.
Algeria tax for expats — country guide Its own page: algeria tax for expats — mechanism, deadlines and published fees.

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 situations we are engaged for

Case study 1

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 2

Treaty Relief Claimed on a Cross-Border Estate

The 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 runs
Case study 3

Green Card Kept, Moved to Canada — Both Returns Still Due

Holding a green card does not end the US filing obligation, and living in Canada starts a Canadian one. The engagement fixes residence under the treaty tie-breaker, then decides which return the relief is claimed on so the two do not contradict each other.

Read how this one runs
Case study 4

A Secondment Whose Paperwork Decided the Tax

Who employs, who directs and who bears the cost are the facts a treaty article turns on, and an assignment letter is where they are recorded. Drafting it with the tax position in view prevents an argument later.

Read how this one runs
Case study 5

Residency Changed Mid-Year and Both Returns Assumed a Full One

A move part-way through a year produces two part-year positions, not two full ones. The engagement establishes the date residence actually changed, allocates income either side of it, and amends whichever return was filed on the wrong footing.

Read how this one runs
Case study 6

A Taxable Presence Created Without an Office

A dependent agent habitually concluding contracts can create a permanent establishment where there is no premises at all. The review tests what the person actually does against what the treaty describes.

Read how this one runs
Case study 7

A Pension Taxed Where the Treaty Did Not Intend

Pension and annuity articles allocate taxing rights differently from employment income, and a flat withholding often exceeds what a return would produce. The alternative filing is elective and has a deadline.

Read how this one runs
Case study 8

A Canadian Property Sale Held Up for a Clearance Certificate

When a non-resident sells Canadian real estate the purchaser must hold back a portion of the price until the seller produces a certificate. The file applies for it on the correct basis and works to the closing date, because the holdback is released against the certificate, not against the sale.

Read how this one runs

All case studies — every published engagement in one place.

Delivery, coverage and how we work

Browse sideways: the pages below answer the neighbouring questions.

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

Software revenue crosses borders by default — sourcing rules, withholding on licence-like payments and IP location decide the effective rate.

Software revenue is rarely taxed where the team sits. Licence, subscription and service income are characterised differently by each side, and the answer decides withholding at source, treaty relief and whether a foreign customer creates a taxable presence at all — questions that are cheap to settle before the contract and expensive afterwards.

  • 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

  • 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

Artistes and sportspersons — the treaty article — questions we are asked

Artistes and sportspersons — the treaty article: 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: gross withholding is common, and it applies to appearance fees, prize money and often a share of endorsement income tied to the event.

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 happens if the two countries disagree about which of them can tax me?

The treaty has a procedure for exactly that. You apply to the competent authority in your residence country, which takes the case up with its counterpart, and the two negotiate a position that removes the double taxation. Some treaties add binding arbitration if they cannot agree. It is slow and it runs on documents, so the practical work is preserving the record and filing protective claims while the clock runs. See our treaty work.

How do I claim a tax treaty benefit?

Three things usually have to line up: proof you are resident of the treaty country, a declaration to whoever is paying you so they withhold at the treaty rate rather than the statutory one, and the claim itself on the return of the country giving relief. Do it before the payment where a reduced rate is available — claimed afterwards it becomes a refund exercise instead, which takes far longer. See certificates of residency.

What is a totalization agreement and how do I use one?

A social security agreement that stops you contributing to two systems for the same work, and lets periods in both count towards benefit eligibility in either. Which system you stay in depends on the agreement's rules for your situation — a seconded employee usually remains in the home system for a set period, a locally hired one usually joins the host system. You evidence it with a certificate of coverage obtained before or shortly after the assignment starts. See certificates of coverage.

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.

Who reviews the work?

A named reviewer signs off every statutory filing, and their name and the review date appear on the advice you receive.

Tax terms explained

Scope boundaryFinCEN 114Clubbing of incomeForm 5471Form 3520Saving clauseBenchmarking studySection 116 certificateForm 15CBHybrid surplusProtective returnForeign earned income exclusionTaxable surplusPAN Browse the full A–Z glossary

Related pages

The rest of this section

All treaties & withholdingTreaty relief for students & researchersWhich treaty wins when three countries applyLower or nil TDS certificate under section 197Competent authority / MAP requestHow to avoid double taxationLimitation on benefits — the treaty test

Adjacent services

Canadian with an offshore accountForm 5472 — foreign-owned US corporationNon-resident student — full-time study deductionsCanadian working in the US — taxes on a TN, H-1B or L-1Form W-8ECI — effectively connected incomeForm 14654 — resident certification

Short answers

How does artistes and sportspersons work in practice?
Fixed fee agreed before we start

Ready to deal with artistes and sportspersons — the treaty article?

Describe what happened and which countries are involved; the fee comes back in writing before anything begins.

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

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