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Open itWhen two countries both call you resident, the treaty breaks the tie in a fixed order. This walks the four rungs in that order, stops at the first one that decides, and prints a record of the facts you entered so you can keep it with the file.
The facts
The name you want used in the record. Nothing depends on which one you put first.
The other country that says you are resident.
Available means at your disposal continuously, not that you were in it. A let property is not available to you.
Tick both if both are available; the ladder then moves down a rung.
Family, social ties, occupation, political and cultural activities, place of business, where assets are managed — taken together, not one at a time.
days
Over the period the treaty looks at, which is usually more than a single year.
days
The same period, counted the same way.
The last rung. If it does not decide either, the two authorities settle it between them.
Treaty resident of
—
Decided at —
Ladder exhausted —
Rungs worked through—
The record, rung by rung
- Enter your figures above and this fills in.
The ladder runs in order, and it stops as soon as it can
The tie-breaker is sequential. You do not weigh the four tests against each other; you take them in order and stop at the first one that produces an answer. That is why a case can turn entirely on whether a home was available — if it was available in one country only, nothing below that rung is ever reached.
Availability is not occupation. A home is available to you if it is at your disposal continuously, furnished and ready, whether or not you slept in it. A property let to a tenant on a real lease is not available to you. A room kept at a relative's house may be.
Why the record matters more than the verdict
An authority that disagrees with your conclusion will not argue about the order of the tests. It will argue about the facts you fed into the rung that decided. So the useful output of this exercise is not the answer — it is the written statement of what was available where, when, and on what evidence.
Print this page once you have entered your facts. The rung that decided is named, the facts behind it are listed in order, and the whole thing is dated by the day you printed it. That is the document a later enquiry is answered from.
Worked example
An engineer moves from Toronto to Bengaluru mid-career. She keeps the Toronto condominium empty for family visits and rents a flat in Bengaluru. Her husband and children are in Bengaluru; her consulting clients are in both places.
- Permanent home: available in both, because the empty condominium is at her disposal. The rung does not decide.
- Centre of vital interests: family and household are in Bengaluru, and that is the stronger pull. The rung decides for India.
- Habitual abode and nationality are never reached, so the day count does not matter to the outcome.
Let the condominium on a twelve-month lease and the first rung decides instead, on availability alone. Same person, same year, different route to the answer — and a much shorter argument.
What this calculator assumes
- The four rungs and their order follow the model convention wording that the India, United States, Canada and Emirati treaties use. A handful of treaties word a rung differently; read yours.
- This decides treaty residence only. Domestic residence, and the filing obligations that come with it, can survive a treaty tie-break — a citizenship-based system in particular.
- The day counts are for the habitual abode rung, which looks at a period longer than one tax year. They are not a substantive presence test.
- A company or trust is broken by a different rule and is not modelled here.
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
- model text OECD Model Tax Convention, Article 4 — resident
- current guidance Canada — determining residency status, CRA
- current guidance United States — tax treaties and dual residence, 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.
Cross-border situations we are engaged for
Case study 1
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 2
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 3
Three Countries in One File and Two Treaties That Disagree
Income sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.
Read how this one runs
Case study 4
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 5
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 6
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 7
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 8
Expanding Abroad — Branch or Subsidiary, Decided on the Numbers
The choice sets the tax on profits, the treatment of early losses, and what it costs to take money home later. The file models all three across the first years rather than deciding on the incorporation cost alone.
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:
