Split-year income allocator
Split the year you moved into resident and non-resident parts and allocate the income.
Open itA cross-border group pays tax three times on the same profit: in the company, at the border, and in the shareholder. This runs all three layers on one set of numbers and shows the combined rate on the money that actually arrives.
The company and the shareholder
$
%
%
%
%
Cash reaching the shareholder
—
Combined rate on the distributed profit —
Layer one — corporate tax—
After-tax profit—
Distributed—
Retained in the company—
Layer two — withholding at the border—
Layer three — personal tax before credit—
Credit for the withholding—
Personal tax after credit—
Withholding with no credit against it—
All three layers—
Three layers, and only one of them is usually quoted
When a group compares two jurisdictions it usually compares corporate rates. That is one layer of three. The border takes a second bite through dividend withholding, and the shareholder's own country takes a third on the same money. A low corporate rate paired with an uncreditable withholding tax can end up more expensive than a higher corporate rate inside a good treaty.
The readout separates the three so you can see which one is actually driving the total. In most structures the third layer is the largest, and the second is the one that can be reduced with paperwork rather than restructuring.
The credit at the top of the chain is where structures fail
Untick the credit box and watch the total. Withholding tax that the shareholder's country will not credit is pure cost, and it is the single most common defect in a cross-border holding structure. It happens when the shareholder is in a country with no treaty, when the dividend is routed through an entity the treaty does not see through, or when the residence certificate simply never reached the payer.
The credit is also capped at the personal tax on the dividend, so a high withholding rate paired with a low personal rate strands the difference. That figure is printed separately for exactly that reason.
Worked example
An operating company earns 500,000 and pays corporate tax at 25%, leaving 375,000. The whole of it is distributed to a shareholder abroad, and the treaty caps dividend withholding at 15%.
- Corporate tax takes 125,000. Withholding takes 56,250 of the 375,000 distributed.
- The shareholder country charges 35% on the 375,000 — 131,250 — and credits the 56,250 withheld, leaving 75,000 to pay.
- Total tax across the chain is 256,250 on 500,000 of profit, and 243,750 reaches the shareholder.
Untick the credit and the same structure costs 312,500 — a 56,250 swing from one piece of paperwork. That is the whole argument for getting the residence certificate to the payer before the dividend is declared.
What this calculator assumes
- One operating company, one shareholder, one distribution. An intermediate holding company adds a layer this model does not have.
- Corporate tax is charged on the whole profit at the rate you enter; no small-company band, loss relief or incentive is applied.
- Dividend relief in the shareholder country should already be folded into the personal rate you type.
- The credit is limited to the personal tax on the dividend. Underlying corporate tax credits, where a country gives them, are not modelled.
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 table Canada — Part XIII rates for non-residents, CRA
- current tables United States — tax treaty tables, IRS
- current list India — DTAA list, Income Tax Department
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.
Cross-border tax case studies
Case study 1
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 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
Wintering in the US Long Enough to Become a US Filer
Days in the United States accumulate across three years, and enough of them make you a US resident for tax regardless of immigration status. The file counts the days properly and files the statement that keeps the position closer connection rather than residence.
Read how this one runs
Case study 4
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 5
Trips That Added Up to a Filing Obligation
Short visits are tracked against a treaty threshold that is measured over a moving window rather than a calendar year. Where the threshold is passed, the obligation reaches back over the whole period.
Read how this one runs
Case study 6
Social Security Contributions Owed in Two Countries at Once
A totalization agreement assigns contributions to one system and exempts the other, but only against a certificate obtained in advance. Without it both sets come out of the same salary and neither is straightforward to recover.
Read how this one runs
Case study 7
A Foreign Affiliate Return Filed Years Late
The reporting obligation on a company held abroad runs separately from the corporate return and carries its own exposure. The work is reconstructing the surplus position across the open years before any filing goes in.
Read how this one runs
Case study 8
Treaty Rate Refused Because the Paperwork Was Missing
A reduced rate under a treaty is available only where the payer is satisfied the recipient is resident in the treaty country. The certificate and the withholding form are what make the rate available at source instead of recoverable a year later.
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
Cross-border tax for sellers shipping worldwide: marketplace withholding, foreign registrations and inventory nexus handled before they become audits.
Marketplaces withhold, remit and report in their own right, so the tax position of a single sale is decided by where the stock sat, where the buyer was and which platform collected — not by where the company is registered. We reconcile the platform's own filings against the returns before either is submitted.
- 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
- 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
Who We Serve:
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Who We Serve:
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:
