6 worked Advance Pricing Arrangement Support case studies — the position a client typically comes to us with, what we do, and what it is worth. Each is an illustrative example built on the rules that apply to advance pricing arrangement support work, not a specific client's file.
Case Study 1 · Structure rebuilt
Corporate Structure Rebuilt For $18,000 Of Annual Savings — US-Facing Canadian Corporation, Edmonton
Client: A Canadian corporation with US customers · Where: Edmonton, Alberta · Engagement: 11 weeks, fixed fee
Saving per year$18,000
DocumentationComplete
Transfer basisRollover
The situation — A Canadian corporation with US customers, Edmonton, Alberta
The structure at a Canadian corporation with US customers in Edmonton, Alberta dated from years earlier. It had been set up for a business that no longer existed. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net had become expensive.
What we did for A Canadian corporation with US customers, Edmonton, Alberta
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result — A Canadian corporation with US customers, Edmonton, Alberta
$18,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 2 · Sale and succession
Share Sale Restructured, $805,000 Less Tax On Closing — Arizona Snowbird, Vancouver
Client: A snowbird spending winters in Arizona · Where: Vancouver, British Columbia · Engagement: 9 weeks, fixed fee
Tax saved on closing$805,000
PriceAs agreed
Post-closing adjustmentsNone
The situation — A snowbird spending winters in Arizona, Vancouver, British Columbia
A snowbird spending winters in Arizona in Vancouver, British Columbia was preparing to sell. Due diligence surfaced a shareholder loan balance that would have been picked up as income on closing. That would have reduced the price or killed the deal outright.
What we did for A snowbird spending winters in Arizona, Vancouver, British Columbia
We cleaned up the historical file. We applied the treaty rate to the dividend withholding, filed the NR4 return, and remitted the shortfall before the CRA assessed the payer for it. Then we prepared the due-diligence package the buyer's advisers actually asked for.
The result — A snowbird spending winters in Arizona, Vancouver, British Columbia
The deal closed at the agreed price. $805,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.
Case Study 3 · Backlog brought current
Collections Halted And $122,000 Cut From A 7-Year Backlog — Non-Resident Landlord, Toronto
Client: A non-resident owning Canadian rental property · Where: Toronto, Ontario · Engagement: 6 weeks, fixed fee
Balance reduced by$122,000
Backlog cleared7 years
CollectionsHalted
The situation — A non-resident owning Canadian rental property, Toronto, Ontario
By the time a non-resident owning Canadian rental property in Toronto, Ontario called, 7 years were outstanding. The CRA had assessed on estimates. Underneath it sat US tax paid but no foreign tax credit claimed on the Canadian return.
What we did for A non-resident owning Canadian rental property, Toronto, Ontario
We reconstructed the records year by year. We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. Each filing replaced an arbitrary assessment with a real one.
The result — A non-resident owning Canadian rental property, Toronto, Ontario
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $122,000, and a relief application addressed part of the accumulated interest.
Case Study 4 · Records and systems rebuilt
29 Months Reconciled And $4,900 Of Input Tax Recovered — US Retirement Account Holder, Guelph
Client: A dual citizen with a US retirement account · Where: Guelph, Ontario · Engagement: 11 weeks, fixed fee
Months reconciled29
Input tax recovered$4,900
Close time9 days
The situation — A dual citizen with a US retirement account, Guelph, Ontario
Nothing reconciled at a dual citizen with a US retirement account in Guelph, Ontario. Every filing started with 29 months of cleanup. The file was carrying invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken.
What we did for A dual citizen with a US retirement account, Guelph, Ontario
We rebuilt from source rather than correcting on top of the existing file. We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. Then we set the routine that keeps it clean.
The result — A dual citizen with a US retirement account, Guelph, Ontario
29 months reconciled to the bank. The close now takes 9 days, and $4,900 of previously unclaimable input tax was recovered in the process.
Case Study 5 · Objection and relief
$99,000 Of Penalties And Interest Cancelled On Relief — Mid-Year Emigrant, Barrie
Client: An emigrant who left Canada mid-year · Where: Barrie, Ontario · Engagement: 6 weeks, fixed fee
Penalties and interest cancelled$99,000
Relief groundsAccepted
AssessmentAdjusted to filed position
The situation — An emigrant who left Canada mid-year, Barrie, Ontario
An assessment of $99,000 landed at an emigrant who left Canada mid-year in Barrie, Ontario following a desk review. It turned on dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability. The auditor had not seen the records behind it.
What we did for An emigrant who left Canada mid-year, Barrie, Ontario
We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. We then set out the legislative basis for the position alongside the documents supporting it.
The result — An emigrant who left Canada mid-year, Barrie, Ontario
$99,000 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.
Case Study 6 · Deadline rescue
Filed On Time From A Standing Start, $38,500 Penalty Avoided — Canadian on US Payroll, Windsor
Client: A Canadian with a US employer · Where: Windsor, Ontario · Engagement: 7 weeks, fixed fee
Penalty avoided$38,500
Turnaround7 weeks
FiledOn time
The situation — A Canadian with a US employer, Windsor, Ontario
A Canadian with a US employer in Windsor, Ontario came to us 7 weeks before its filing deadline. The file came with winters spent in the United States with the day count kept casually and no residency position documented anywhere. A late filing would have triggered a penalty of roughly $38,500 before interest.
What we did for A Canadian with a US employer, Windsor, Ontario
We worked backwards from the deadline. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We prioritised the items that actually gated the filing and deferred everything that did not.
The result — A Canadian with a US employer, Windsor, Ontario
The return was filed on time and complete. The $38,500 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.
Reviewed by Udit Gupta, Founder and Tax Accountant for the 2025 tax year. These case studies are illustrative worked examples composed from the CRA rules that apply to this type of work, not specific client files; figures are representative and outcomes depend on your own facts.
