6 worked Canada-US Tax Accountant 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 canada-us tax accountant work, not a specific client's file.
Case Study 1 · Backlog brought current
$136,000 Of Arbitrary Assessments Vacated After 5 Years — US Branch Operator, Burnaby
Client: A Canadian corporation operating a US branch · Where: Burnaby, British Columbia · Engagement: 11 weeks, fixed fee
Arbitrary tax vacated$136,000
Years brought current5
Account statusCurrent
The situation — A Canadian corporation operating a US branch, Burnaby, British Columbia
5 years of unfiled returns had turned into notional assessments at a Canadian corporation operating a US branch in Burnaby, British Columbia. Underneath lay 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. Collections had already started.
What we did for A Canadian corporation operating a US branch, Burnaby, British Columbia
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. We then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.
The result — A Canadian corporation operating a US branch, Burnaby, British Columbia
All 5 years were accepted as filed. $136,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 5 years.
Case Study 2 · Structure rebuilt
Corporate Structure Rebuilt For $24,500 Of Annual Savings — US-Facing Canadian Corporation, Brampton
Client: A Canadian corporation with US customers · Where: Brampton, Ontario · Engagement: 11 weeks, fixed fee
Saving per year$24,500
DocumentationComplete
Transfer basisRollover
The situation — A Canadian corporation with US customers, Brampton, Ontario
The structure at a Canadian corporation with US customers in Brampton, Ontario dated from years earlier. It had been set up for a business that no longer existed. US tax paid but no foreign tax credit claimed on the Canadian return had become expensive.
What we did for A Canadian corporation with US customers, Brampton, Ontario
We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. 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, Brampton, Ontario
$24,500 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 3 · Sale and succession
Share Sale Restructured, $395,000 Less Tax On Closing — Inbound Assignee, Regina
Client: An inbound transferee on assignment · Where: Regina, Saskatchewan · Engagement: 10 weeks, fixed fee
Tax saved on closing$395,000
PriceAs agreed
Post-closing adjustmentsNone
The situation — An inbound transferee on assignment, Regina, Saskatchewan
An inbound transferee on assignment in Regina, Saskatchewan was preparing to sell. Due diligence surfaced retained cash well above what the business needed to operate. That would have reduced the price or killed the deal outright.
What we did for An inbound transferee on assignment, Regina, Saskatchewan
We cleaned up the historical file. We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. Then we prepared the due-diligence package the buyer's advisers actually asked for.
The result — An inbound transferee on assignment, Regina, Saskatchewan
The deal closed at the agreed price. $395,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.
Case Study 4 · Deadline rescue
5-Week Turnaround Beat The Deadline And Saved $15,500 — US Rental Owner, Kitchener
Client: A Canadian resident with a US rental property · Where: Kitchener, Ontario · Engagement: 5 weeks, fixed fee
Late-filing penalty avoided$15,500
Filed with16 days to spare
Next yearPapers ready
The situation — A Canadian resident with a US rental property, Kitchener, Ontario
A Canadian resident with a US rental property in Kitchener, Ontario was weeks away from the deadline for Canada-US tax accountant. Behind that sat foreign accounts that had passed the $100,000 T1135 threshold three years earlier. The exposure if the date slipped was around $15,500.
What we did for A Canadian resident with a US rental property, Kitchener, Ontario
We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. The filing went in complete rather than provisional, so there was no amended return to follow.
The result — A Canadian resident with a US rental property, Kitchener, Ontario
Filed with 16 days to spare. $15,500 in late-filing penalties avoided, and the working papers are ready for the following year.
Case Study 5 · Records and systems rebuilt
Books Rebuilt From Source, $20,000 In Unclaimed Input Tax Found — Mid-Year Emigrant, Red Deer
Client: An emigrant who left Canada mid-year · Where: Red Deer, Alberta · Engagement: 3 weeks, fixed fee
Unclaimed tax found$20,000
Records rebuilt24 months
ProcessDocumented
The situation — An emigrant who left Canada mid-year, Red Deer, Alberta
An emigrant who left Canada mid-year in Red Deer, Alberta could not answer basic questions about its own numbers. A departure year filed as a normal resident return with no deemed disposition reported sat between the bank statements and the ledger.
What we did for An emigrant who left Canada mid-year, Red Deer, Alberta
We registered the payer for a non-resident withholding account, remitted the Regulation 105 amounts due, and applied for waivers covering the rest of the contract. We then documented the process so the work does not depend on any one person remembering how it was done.
The result — An emigrant who left Canada mid-year, Red Deer, Alberta
Records rebuilt and reconciled, $20,000 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.
Case Study 6 · Objection and relief
Desk-Review Assessment Of $85,000 Vacated — Florida Property Owner, Victoria
Client: A family with a Florida vacation property · Where: Victoria, British Columbia · Engagement: 7 weeks, fixed fee
Assessment vacated$85,000
Supporting recordsNow on file
AccountCleared
The situation — A family with a Florida vacation property, Victoria, British Columbia
A family with a Florida vacation property in Victoria, British Columbia was carrying $85,000 of penalties and interest. The charges arose from invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken. Much of that amount accumulated during a period the CRA itself had delayed.
What we did for A family with a Florida vacation property, Victoria, British Columbia
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. We framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A family with a Florida vacation property, Victoria, British Columbia
The assessment was vacated. $85,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
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.
