Low-cost Regulation 105 waiver

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Withholding on fees for services rendered in Canada is computed on gross fees, which routinely exceeds the non-resident's eventual Canadian tax by a multiple. Low-cost regulation 105 waiver with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

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  • 15+Years of cross-border experience
  • 18,000+Clients served
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  • 4Global offices — India, USA, Canada & UAE
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Secure a fixed quote

First we read your documents, then you get the price in writing, and only then does the work begin.

24-hour helpline: +1 (416) 619-0068
  • 18,000+ clients served
  • 24-hour helpline: +1 (416) 619-0068
  • Google rating 5.0 out of 5
The short answer

Withholding on fees for services rendered in Canada is computed on gross fees, which routinely exceeds the non-resident's eventual Canadian tax by a multiple. A waiver can be sought on a treaty basis or on an income-and-expense basis, and it must be applied for before the fee is paid.

Who has to deal with this

  • A lender, buyer or investor has started asking tax questions
  • The board has never seen the group's tax exposures written down
  • Advice was taken years ago and the rules have moved since
  • Two advisers in two countries have given you inconsistent answers
  • Substance was never documented for an entity that relies on it

If any of that is familiar, keep reading. If none of it is, the shortest route is to describe your own situation and let us name the right page for it.

The firm’s founder at his desk in the Delhi office

What regulation 105 waiver costs here

A waiver application against withholding on fees for services rendered in Canada is priced on the number of contracts and payers in scope and on which basis is argued — the treaty one, or the income-and-expense route, which needs a budget of Canadian costs built from your own records. Filing before the fee is paid is the shorter job.

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

Registrations, withholding and the employer obligations that follow staff working across a border, set up once and correctly.
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

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

Non-resident & departure filings

From $349

fixed, quoted before work starts

Non-resident filings and the two part-year returns a move produces, sequenced so neither country taxes the same income twice.
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

Missed years brought current under the disclosure programme that fits, with the penalty position worked out before anything is filed.
See the fee schedule

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

The mechanism, in plain terms

Withholding on fees for services rendered in Canada is computed on gross fees, which routinely exceeds the non-resident's eventual Canadian tax by a multiple.

A waiver can be sought on a treaty basis or on an income-and-expense basis, and it must be applied for before the fee is paid. Without it the money is recovered only by filing a Canadian return for the year.

Put the other way round: the return is the last step, not the work. What decides regulation 105 waiver is the set of facts in place when the year closes, and those facts are the part a client can still influence when they come to us early enough.

Thresholds and rates move, and summaries written for last year are not evidence about this one. So each figure in your file is sourced to the issuing authority for the specific year; anything we cannot source, we describe as a mechanism and leave unquantified until it can be confirmed. See also India–United Kingdom tax corridor and Canadian with foreign inheritance.

What we actually file

  • A second-opinion memorandum on the existing arrangement
  • Implementation steps mapped to their deadlines
  • A written structure review with the positions and their support
  • The filing calendar, by entity and jurisdiction, with owners
  • The elections and disclosures the plan depends on

A worked example

Put numbers against it and the shape of the answer is obvious.

Gross withholding against a net-basis return

A non-resident receives C$29,000 in the year. Assume withholding at 30% on the gross amount, and assume deductible costs of C$19,720 against it.

ItemAmount
Gross amount receivedC$29,000
Withheld at source (assumed 30% of gross)C$8,700
Deductible costsC$19,720
Net amount actually earnedC$9,280
Tax on the net amount (assumed graduated result)C$2,134
Difference recoverable by filingC$6,566

Filing on a net basis recovers C$6,566 of the C$8,700 withheld. That difference is the entire reason the elective return exists, and it is lost by not filing. The shape of that result holds; the size of it depends entirely on your own numbers and dates.

Illustrative figures, not a client engagement: the amounts are chosen to make the mechanism legible, and the rates and thresholds are assumptions stated for the example only. We confirm every one of them against the issuing authority for your own tax year before anything is filed.

How we handle it

  1. 1We establish what happened and when, because every position here is anchored to a date
  2. 2A written scope and a fixed price, so you know the cost before committing
  3. 3The filings are prepared, cross-checked against each other, and reviewed by name
  4. 4You see the result, approve it, and we file it

Fees for this work

Fees for regulation 105 waiver 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.

  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
  • Documents move through one secure portal, and you can meet us in person at any of our offices.
  • Nothing is filed until you have read it.

Where to go from here

If you already have an adviser, we will tell you what they should be asking rather than replacing them. The fastest start is a short call and three things: what happened, when it happened, and which countries are involved. Everything else we can ask for as it comes up.

Reviewed 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.

US tax treaties, in practice

The subject here is regulation 105 waiver, which is what people mean when they search for US tax treaties. This page covers who it applies to, the filings it produces, and the fixed fee agreed before work begins.

Withholding on fees for services rendered in Canada is computed on gross fees, which routinely exceeds the non-resident's eventual Canadian tax by a multiple.

From first contact to filed return

  1. Share your documents

    A secure upload link arrives after the first call — send files in any state.

  2. A written fixed fee

    The quote is fixed from what you send; it does not move once accepted.

  3. Preparation, both sides at once

    The returns are drafted together, reconciled line against line.

  4. Approve, then file

    Nothing is filed until you have seen it and approved it.

The difference a dedicated cross-border team makes

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

Key terms behind this page, defined

Foreign grantor trust
A non-US trust with a US settlor treated as grantor, bringing US information reporting and taxation of the trust's income to that settlor.
Non-resident trust
A trust outside the country that can nonetheless be deemed resident because a resident contributed to it or benefits from it.
Tax equalisation
A policy under which the employer bears the actual host and home tax and deducts a hypothetical home tax from the employee.
Chapter 4 withholding
The FATCA withholding regime, which turns on an institution's or entity's status classification rather than on the character of the income.
regulation 105 waiver: The practitioner's note

A waiver can be sought on a treaty basis or on an income-and-expense basis, and it must be applied for before the fee is paid.

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

Fixed fees around regulation 105 waiver

Where no waiver was obtained and the gross withholding has already been taken, the money comes back only through a Canadian return for that year, so the fee then follows the number of years and the state of the expense records. Both routes are quoted in writing before anything is prepared.

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 regulation 105 waiver

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.

We say early if it is not our work

If a file needs something this practice does not do, you hear that at the start rather than after a bill.

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.

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.

The team at work in the open-plan office

Regulation 105 waiver — the four phases

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

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

The engagement, start to finish

  • Step 1: Send the documents as they are – No tidying required — forward what you have and we tell you what is missing.
  • Step 2: Get a fixed quote in writing – Priced from your actual documents before any work begins, not estimated after.
  • Step 3: Both countries prepared together – One team builds the filings against each other so the relief lands exactly once.
  • Step 4: Review, then file – You approve the finished work before we file it.

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.

Services these clients use most

Form 14653 — non-resident certification Everything on form 14653 non resident certification, at the same depth as this page.
Form T2062B — life insurance disposition T2062b life insurance disposition — the guide, the FAQ and the fixed fee.
Form 2555 — foreign earned income exclusion The full guide to foreign earned income exclusion, with the fee fixed before any work starts.
Form W-8BEN-E — entity treaty claim for Canada Its own page: w8ben Canada tax treaty — mechanism, deadlines and published fees.
Form T1161 — list of properties on emigration Everything on T1161 list of properties emigration, at the same depth as this page.
Form RC1 — business number registration Rc1 business number registration — the guide, the FAQ and the fixed fee.
TP audit defence file The full guide to tp audit defence file, with the fee fixed before any work starts.
MAT and AMT for foreign-owned companies Its own page: mat and amt for foreign-owned companies — mechanism, deadlines and published fees.
Form 706-NA — non-resident estate return Everything on form 706-na non resident estate return, at the same depth as this page.

Who we bring this work to

Seafarers & mariners — your filing calendar Everything on seafarers & mariners your filing calendar, at the same depth as this page.
Tax for management consultants Management consultants tax — the guide, the FAQ and the fixed fee.
Technology & SaaS — your filing calendar The full guide to technology & saas your filing calendar, 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.
Tax for non-resident landlords Everything on non-resident landlords tax, at the same depth as this page.
Tax for travel nurses (us contracts) Travel nurses (US contracts) tax — the guide, the FAQ and the fixed fee.
Airline pilots — what we charge The full guide to airline pilots what we charge, with the fee fixed before any work starts.
Cross-border truck drivers — your filing calendar Its own page: cross-border truck drivers your filing calendar — mechanism, deadlines and published fees.
App & game studios cross-border tax Everything on app & game studios cross border tax, at the same depth as this page.

Countries and corridors this work reaches

India–United Kingdom tax corridor Everything on India United Kingdom tax, at the same depth as this page.
Norway tax for expats — country guide Norway tax for expats — the guide, the FAQ and the fixed fee.
Bulgaria tax for expats — country guide The full guide to bulgaria tax for expats, with the fee fixed before any work starts.
Uganda tax for expats — country guide Its own page: uganda tax for expats — mechanism, deadlines and published fees.
Malta tax for expats — country guide Everything on Malta tax for expats, at the same depth as this page.
Costa Rica tax for expats — country guide Costa Rica tax for expats — the guide, the FAQ and the fixed fee.
Belgium tax for expats — country guide The full guide to Belgium tax for expats, with the fee fixed before any work starts.
Oman tax for expats — country guide Its own page: Oman tax for expats — mechanism, deadlines and published fees.
Finland tax for expats — country guide Everything on Finland 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

Cross-border tax case studies

Case study 1

One Salesperson Abroad, and a Corporate Filing Obligation

A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to it.

Read how this one runs
Case study 2

Paid for Work Done in Canada While Living Elsewhere

Employment carried out in Canada is taxable here even where the employer and the bank account are not. The engagement establishes how many of the days were worked in Canada, applies the treaty employment article, and deals with the withholding the payer has already taken.

Read how this one runs
Case study 3

Canadian Pension Paid Abroad and Taxed at the Flat Rate

Pension and annuity payments to a non-resident carry a flat withholding that often exceeds what a return would produce. The alternative filing is elective, and whether it helps depends on the total income for the year rather than on the payment alone.

Read how this one runs
Case study 4

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 5

A Residency Determination Review After Leaving the Country

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

Read how this one runs
Case study 6

An Assignment Priced Without Counting the Days

Nearly every relief in a mobility file — treaty exemption, residence, social security — is decided by a day count that has to be evidenced. The engagement puts the tracking in place at the start, because it cannot be reconstructed at the end.

Read how this one runs
Case study 7

Withholding Reduced by the Right Article

Dividends, interest and royalties each have their own article and their own rate, and the payer applies whichever it is satisfied of. Establishing entitlement before payment is what secures the lower rate at source.

Read how this one runs
Case study 8

A Canadian Landlord With Property in the United States

Gross withholding on US rents takes no account of mortgage interest, tax or repairs, so a leveraged property can face tax on turnover. An election onto net basis fixes that, and it has its own timing and its own filing.

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

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

Regulation 105 waiver — questions we are asked

Regulation 105 waiver — do I need an adviser, or can I do it alone?

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: a waiver can be sought on a treaty basis or on an income-and-expense basis, and it must be applied for before the fee is paid.

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.

Is my foreign pension taxable?

Usually in at least one country, and which one depends on the treaty article covering pensions — some give the taxing right to the country paying it, others to where you live, and several treat government service pensions differently again. Withholding at source is common and often reducible by treaty, with an elective return recovering an over-deduction. See the pensions article.

What is Part XIII withholding tax in Canada?

Part XIII is the Canadian charge on certain amounts paid to non-residents — rent, dividends, interest, royalties, pensions and similar passive income. The payer withholds and remits it, and it is a flat charge on the gross payment rather than on profit, which is why a non-resident landlord can be withheld on far more than the net rental result. Treaties reduce the rate and elective returns recover the excess. See the section 216 return.

What is the MLI, and could it have changed my treaty?

The Multilateral Instrument is a single convention that amends many bilateral treaties at once, so countries did not have to renegotiate each one. Where both countries adopted a provision, it overrides the older text — most consequentially a principal-purpose test that can deny a benefit where obtaining it was a main reason for the arrangement. Reading the original treaty alone is therefore not safe. See our treaty work.

How far back can you go?

As far as the records allow. Whether a year can still be corrected, and whether a refund is still claimable in it, are two different questions and we answer both before proposing anything.

Do you use software I need to learn?

No. You send documents through the portal and receive the finished filings back; everything else happens on our side.

Tax terms explained

PFICEqualisation levyDeparture taxPlace of supplyDeemed dividendDay-count recordBusiness purpose testBenchmarking studyTreaty overrideNRO accountGraduated rate estateStaking rewardWrapped assetGILTI Browse the full A–Z glossary

Related pages

The rest of this section

All treaties & withholdingUS–India treaty explainedTreaty residency tie-breaker (Article IV)Withholding refund & recovery claimsMLI & the principal-purpose testPensions and annuities — the treaty articleWhich treaty wins when three countries apply

Adjacent services

Repatriating money out of IndiaNon-resident rental income from Canadian propertyCanada–Germany tax corridorUS–United Kingdom tax corridorNRI Indian return — do you need to declare foreign assets?Form 8288-A — FIRPTA statement

Short answers

How does regulation 105 waiver work in practice?
Meet us in person at any of our offices

Get regulation 105 waiver handled for a fixed fee

One short call, one fixed quote in writing, and your approval before anything is filed.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • 18,000+ clients served
  • Offices in India, the USA, Canada and the UAE
  • 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