Economical Social security totalization agreements — Canada and the US

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Social security is not covered by the tax treaty. Economical social security totalization agreements 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
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
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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
  • 15+ years of cross-border experience
  • 24-hour helpline: +1 (416) 619-0068
  • Fixed fee agreed before work starts
The short answer

Social security is not covered by the tax treaty. The agreement prevents contributions to both systems and allows periods to be aggregated for benefit eligibility.

Whether this is your situation

  • Equity was granted in one country and vests in another
  • You cannot produce a day-count record for the year
  • Staff travel to work at customer sites abroad
  • A local authority has queried why no payroll is registered
  • Social security is being paid to two systems for the same person

That list is deliberately concrete. If you recognise yourself in it, this page is the right starting point; if you do not, tell us and we will point you elsewhere without charging for it.

The team reviewing a file together at a desk

Fixed fees for social security totalization agreement Canada US, agreed up front

What drives the fee on a totalization certificate of coverage is how many people are being posted and in which direction, since each worker's certificate is applied for from their home authority. Where both social security systems have already billed for the same person, unwinding the double contribution is a separate and larger piece of work.

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

Cross-border payroll setup — fixed-fee price

From $999

fixed, quoted before work starts

Registrations, source deductions and reporting in the country of work, plus the social security certificate and the day-count discipline that supports the position.
See the full fee page

Individual tax filing

From $349

fixed, quoted before work starts

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

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

Corporate cross-border filing

From $999

fixed, quoted before work starts

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

Non-resident & departure filings

From $349

fixed, quoted before work starts

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

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

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

All published fees on one page — the complete list of what each engagement costs, stated as figures rather than ranges.

How the rule actually works

Social security is not covered by the tax treaty. A separate agreement decides which country's system a cross-border worker pays into, and it is evidenced by a certificate of coverage.

The agreement prevents contributions to both systems and allows periods to be aggregated for benefit eligibility. The certificate is applied for from the home authority before or at the start of the assignment; without it, both systems bill.

Two things follow from that. The first is that the outcome is decided by facts you can arrange and evidence you can keep, rather than by how the return is completed at the end of the year. The second is that sequence matters: the same steps taken in a different order can produce a materially different result, which is why the first conversation is about dates and documents rather than forms.

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 form 8804 / 8805 — partnership withholding and India–Australia tax corridor.

What we actually file

  • Assignment documentation that settles who the employer actually is
  • Day-count records assembled from travel data
  • Year-end reconciliations between the two payrolls
  • Host and home payroll registrations and returns
  • Waivers and certifications that remove withholding where a treaty applies

A worked example

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

Splitting one salary between two countries

A salary of C$136,000 for a year with 244 working days, 88 of them performed in the other country. Employment income is generally sourced to where the work was physically done.

ItemAmount
Annual salaryC$136,000
Working days in the year244
Days worked in the other country88
Days worked at home156
Income sourced to the other countryC$49,049
Income sourced at homeC$86,951

C$49,049 is sourced abroad on this split, which is the figure the host country taxes and the figure the home credit is computed on. Reproduce this from a travel record, not from memory — it is the first thing an auditor asks for. 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 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

What it costs

What it costs is settled at the start. We establish the scope on a short call, quote a fixed fee against it in writing, and that is the number on the invoice. Comparable engagements and their fixed fees are set out on the pricing pages.

  • Authorisation with each authority, so we see the assessments and slips directly rather than asking you for them.
  • 18,000+ clients served across 4 global offices: India, the USA, Canada and the UAE.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.

What to do next

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 social security totalization agreements — Canada and the US engagement is working out which documents actually matter, and that is quicker with a partial pack than with none.

Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

Tax treaty agreement — what this page covers

Read this page for tax treaty agreement. It works through social security totalization agreements from the beginning — whether it applies to you at all, what has to be filed if it does, and what the engagement costs, priced up front.

People also search for: double tax · international tax planning · tax articles · double tax treaty · tax planning international.

Social security is not covered by the tax treaty.

The four phases of the work

  1. Hand over the paperwork in any state

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

  2. Priced before a single form is opened

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

  3. One position across every return

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

  4. Filed after you have read it

    The completed work reaches you before it reaches an authority.

How social security totalization agreement Canada US 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

Engagement letter
The document setting the scope, the fee and the boundary with any other adviser. In a cross-border file the boundary is the important part.
Specified foreign property
The class of property reportable on Canada's foreign property statement. Property held inside Canadian registered plans and some other holdings are treated differently.
Delinquent FBAR
A late account report filed with a reasonable-cause statement where the income was reported and no examination is under way.
Exempt surplus
A pool of a foreign affiliate's active business earnings from a treaty or agreement country, dividends from which can generally reach Canada without further Canadian tax.
social security totalization agreement Canada US: The practitioner's note

The agreement prevents contributions to both systems and allows periods to be aggregated for benefit eligibility.

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.

Social security totalization agreement Canada US — what the published fees look like

The published fees below are for the ordinary case: one posting, one certificate, arranged at the start of the assignment. Longer secondments that need the coverage extended, self-employed people who fall under the agreement's own rule, and claims that aggregate periods across both systems for benefit eligibility are scoped on the facts and quoted in writing.

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

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

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

The difference a dedicated cross-border team makes

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.

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.

Both sides prepared together

Two returns built against each other by one team, so relief is claimed exactly once and nothing falls between the two systems.

Cross-border is the whole practice

International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.

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

From first call to filed return

Step 1

Initial call

We start with the chronology: dates, countries, and what has already been filed

Step 2

Scope and fee

You get the scope and the fee in writing before we touch anything

Step 3

Preparation and review

The work is prepared and reviewed by a named person, not a queue

Step 4

Filing and payment

Nothing is filed until you have read it

The team at work in the open-plan office

From first document to filed return

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

Quoted up front, in writing.

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

Keep reading, sideways

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

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Form T2036 — provincial foreign tax credit Everything on t2036 provincial foreign tax credit, at the same depth as this page.
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Form 2553 — S-corporation election The full guide to form 2553 s corporation election, with the fee fixed before any work starts.
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Form T2209 — federal foreign tax credit Everything on T2209 federal foreign tax credit, at the same depth as this page.
International tax planning International tax planning — the guide, the FAQ and the fixed fee.

Clients who arrive with this exact page

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Tax for non-resident landlords Its own page: non-resident landlords tax — mechanism, deadlines and published fees.
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Where our clients live and work

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Chile tax for expats — country guide Its own page: Chile tax for expats — mechanism, deadlines and published fees.
Ghana tax for expats — country guide Everything on Ghana tax for expats, at the same depth as this page.
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The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

Cross-border situations we are engaged for

Case study 1

US Estate Tax on Assets a Canadian Did Not Know Were Exposed

US shares and US real estate sit inside the US estate tax net regardless of where the owner lives. The treaty provides relief that is proportionate rather than automatic, and the calculation depends on the worldwide estate.

Read how this one runs
Case study 2

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 3

A Distribution From a Trust Set Up Abroad

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

Read how this one runs
Case study 4

A US Citizen Settled in India, Filing on Both Sides

Residence in India and citizenship in the United States produce two annual returns for one income. The order decides the credit, and the Indian financial year and the US calendar year have to be reconciled before either is prepared.

Read how this one runs
Case study 5

A Student or Researcher Covered by a Treaty Article

Several treaties carry a dedicated article for students, trainees and visiting researchers that displaces the ordinary employment rules. Whether it applies turns on the purpose of the stay and the source of the funds, both of which are evidenced rather than asserted.

Read how this one runs
Case study 6

Which Country Taxes the Salary

The employment article turns on where the work is done, who pays, and who bears the cost — three tests that can point in different directions. The file establishes all three before either return is drafted.

Read how this one runs
Case study 7

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 8

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

All case studies — every published engagement in one place.

Delivery, coverage and how we work

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

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

Social security totalization agreements — Canada and the US — questions we are asked

Social security totalization agreements — Canada and the US: what part of this actually needs a professional?

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: the agreement prevents contributions to both systems and allows periods to be aggregated for benefit eligibility.

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.

Can I move my 401(k) or IRA into an RRSP?

In limited circumstances, and rarely without cost. Canada allows a transfer of certain US plan proceeds into an RRSP with additional room for that purpose, but the withdrawal is a taxable distribution on the US side first, with withholding and potentially an additional charge for taking it early. Whether the Canadian credit fully absorbs that US tax is the calculation that decides it. Often leaving the plan where it is and drawing later is the better answer. See RRSP against 401(k) and IRA.

What is a double tax treaty and what does it actually do?

It is an agreement between two countries that divides up the right to tax. Article by article it decides which country taxes employment income, dividends, interest, royalties, pensions, property and business profits — and where both may tax, it caps what the source country can withhold and tells the other to give credit. It also breaks residence ties and opens a government-to-government channel for disputes. What it never does is apply itself: a treaty position is claimed. See our treaty work.

What is a tax treaty?

A bilateral agreement that allocates taxing rights between two countries so the same income is not taxed twice without relief. It decides which country may tax each income type, caps withholding rates at source, and supplies a tie-breaker when both countries consider you resident. A treaty does not reduce tax automatically — you claim its benefit on a return, a withholding form or a residency certificate. Tax treaty vs domestic law shows how the two interact.

Why do you not publish more numbers on the site?

Because thresholds and rates move, and a stale figure on a page is the one that gets copied into a filing. Where we can verify a figure for the year we publish it with its source; where we cannot, we explain the mechanism instead.

What is the most common thing you find on a review?

An unclaimed foreign tax credit, a missed information return, and a treaty position taken without the disclosure the rules required. Usually all three.

Tax terms explained

CbCRZero-rated supplyUS estate taxLRSTreaty overrideContemporaneous documentationBEPSBEATResale price methodDual-status alienProfit splitTransfer certificateClubbing of incomePublished fee Browse the full A–Z glossary

Related pages

Nearby pages

All treaties & withholdingTreaty shopping & beneficial ownershipWhich treaty wins when three countries applyTreaty relief on RRSP / 401(k) / IRAUS 30 percent withholding and treaty ratesPart XIII withholding reviewRegulation 105 waiver

Where this leads next

Form 8288-B — withholding certificateMoving to Canada — a newcomer's first return and benefit claimsCanada–Germany tax corridorCanada–Australia tax corridorIndia–Australia tax corridorForm 7004 — business extension

Questions on this

How does social security totalization agreements work in practice?
Meet us in person at any of our offices

Talk to us about social security totalization agreements — Canada and the US

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
  • Offices in India, the USA, Canada and the UAE
  • Re-quoted, never silently invoiced
  • 24-hour helpline, +1 (416) 619-0068

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

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