Split-year income allocator
Split the year you moved into resident and non-resident parts and allocate the income.
Open itPick the kind of income and enter the rate each country would charge. The allocator names the country with the first taxing right, shows the credit the other one gives, and adds up what the item actually costs across both returns.
The item of income
The article that governs the item is what decides the answer, so this is the first question, not the amount.
$
Before any tax is taken off, in one currency throughout.
%
The domestic withholding or assessment rate the paying country would apply.
%
Only used for dividends, interest and royalties. Read your treaty article rather than assuming a figure.
%
The rate the country you live in would charge on the same income.
A few treaties use exemption rather than credit for some items. Leave it unticked for the ordinary credit method.
Combined tax on this item
—
Effective rate across both countries —
First taxing right—
Source tax without the treaty—
Source rate actually applied—
Source tax as applied—
Saved by the treaty cap—
Residence tax before relief—
Credit for the source tax—
Residence tax after relief—
Source tax with no credit against it—
Left in your hand—
How a treaty splits one item of income between two countries
A treaty does not stop two countries taxing the same money. It decides which of them goes first, caps what the first one may take on some kinds of income, and makes the second one give credit for what the first one took. That is why the answer to "who taxes this?" is almost always "both, in a particular order".
The order depends on the item, not on the amount. Immovable property is taxed where it sits. Business profits reach the source country only through a permanent establishment there. Employment income follows the place the work was physically done. Dividends, interest and royalties are shared: the source country keeps a capped slice and the residence country taxes the gross figure and hands back a credit. A residual article sweeps up whatever is left and usually leaves it to the residence country alone.
Why the credit is often smaller than the tax it is meant to relieve
A credit is limited to the residence country's own tax on the same income. If the source country charged more than the residence country would have, the difference is not refunded — it is simply lost, unless the domestic rules let it carry to another year. The allocator prints that number separately, because it is the one people miss when they compare two structures.
The other trap is the capped rate. A treaty caps what the source country may charge, but the payer applies the domestic rate unless you put the paperwork in front of them first. The cap is a right you claim, not a rate that arrives by itself.
Worked example
An Indian-resident engineer holds shares in a Canadian company and receives a dividend of 100,000. Canada's domestic withholding rate on a dividend to a non-resident is higher than the rate the treaty allows, and India taxes the dividend as ordinary income at the engineer's marginal rate.
- Canada withholds at the capped rate, not the domestic one — but only if the residence certificate reached the payer before the payment.
- India taxes the gross 100,000 at the marginal rate, then credits the Canadian tax against it.
- The credit is capped at the Indian tax on that dividend. Any Canadian tax above that figure has no Indian tax left to sit against.
Change the treaty cap in the panel to see the whole chain move. The gap between the domestic rate and the cap is the value of getting the paperwork in on time.
What this calculator assumes
- The allocation follows the pattern the model convention sets and that most India, United States, Canada and Emirati treaties adopt. Your treaty is what governs — read its article before relying on the order shown.
- One item of income at a time, one currency throughout. Nothing here converts currency or aggregates a return.
- The credit is limited to the residence country tax on the same income. Carryback and carryforward of the excess are domestic questions, not treaty ones.
- No surcharge, cess, state or provincial layer is added unless you fold it into the rate you type.
An estimate, not advice. This is an estimate built from what you typed, not advice on your file. Nothing here reads your documents, checks your treaty article or looks at the year you are actually in. Where the number matters, we agree a fixed fee in writing before any work starts.
Where these figures come from
- current list Canada — tax treaties in force, Department of Finance
- current list India — double taxation avoidance agreements, Income Tax Department
- current list United States — tax treaty tables, IRS
Any figure prefilled in the panel above is stated with the year it belongs to and can be changed. Rates and thresholds move; a calculator that asks you for the current one stays right, and one that hides a guess does not.
What these engagements turn on
Case study 1
A Penalty Argued on the Facts Rather Than the Form
Reasonable cause is a documented story with dates, not an assertion of good intent. The engagement assembles what the client actually knew and when, and puts the sequence in writing alongside the filings it explains.
Read how this one runs
Case study 2
A Foreign Property Form Filed Late, With Penalties Running Daily
The foreign asset return carries a penalty that accrues per day rather than per return, so the exposure grows quietly. Relief is discretionary and it is granted on the reasons given, which means the request is the work rather than the form.
Read how this one runs
Case study 3
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 4
Social Security Paid Twice Until a Certificate Arrived
Income tax relief does not reach a social security charge; only an agreement does, and only against a certificate from the system actually being paid into. Obtaining it is the work, and it is often retrospective.
Read how this one runs
Case study 5
A Retirement Plan That Grows Tax-Deferred in Only One Country
Cross-border retirement accounts are recognised by treaty, but the deferral usually has to be elected rather than assumed. The engagement checks whether the election was made, makes it where it was missed, and reports the account on whichever side requires it.
Read how this one runs
Case study 6
Ten Years of Missed Returns Filed as One Engagement
Filing many years at once is a sequencing problem: carry-forwards, instalments and credits from the earliest year feed the latest. Filing them out of order is what turns a recoverable position into an assessed one.
Read how this one runs
Case study 7
Never Filed a US Return — and Only Just Found Out
Born in the United States, left as an infant, and told by a bank that the returns were owed all along. The work is sequencing: establish which years are actually open, choose the catch-up route on the facts rather than filing quietly, and claim the exclusions and credits that were never taken.
Read how this one runs
Case study 8
An Assignee Paid at Home and Taxable Away
Where pay stays on the home payroll but the tax arises elsewhere, a shadow run reports the second country's liability without duplicating the payment. Setting it up correctly is what keeps both sides reconcilable.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.
U.S. & Cross-Border Tax Returns
Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.
Expat & Emigration Tax
The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.
Non-Resident Canadian Tax
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.
Transfer Pricing & BEPS
Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.
Tax Treaties & Withholding
Relief is only as good as the paperwork claiming it — we build treaty positions that survive review on both sides.
Cross-Border Estates & Trusts
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Global Investments & Reporting
Information returns carry the sharpest penalties — $25 a day whether or not any tax is owing. We keep them clean and on time.
Cross-Border Corporate Tax
Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.
India Tax for NRIs & Returning Residents
The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.
Canadian Tax with a Foreign Element
Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.
UAE Tax for Expats & Their Home Country
A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Who We Serve:
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Who We Serve:
Professional Services Firms
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Who We Serve:
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Who We Serve:
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
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Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
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Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Who We Serve:
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
Who We Serve:
