Canadian Moving to the United States Tax Planning Case Studies
6 worked Canadian Moving to the United States Tax Planning 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 canadian moving to the united states tax planning work, not a specific client's file.
Case Study 1 · Records and systems rebuilt
Month-End Close Cut From 10 Weeks To 7 Days — Cross-Border Contractor, Ottawa
Client: A contractor working on both sides of the border. Where: Ottawa, Ontario. Engagement: 11 weeks, fixed fee.
Close time before10 weeks
Close time after7 days
Year-endReview, not rebuild
Case 1: the situation
The accounting file at a contractor working on both sides of the border in Ottawa, Ontario had a weak foundation. It was built on a departure year filed as a normal resident return with no deemed disposition reported. The year-end had taken 10 weeks each of the last three years.
Case 1: what we did
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. We also moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.
Case 1: the result
The file reconciles. Month-end closes in 7 days instead of 10 weeks, and the year-end is a review rather than a reconstruction.
Case Study 2 · Objection and relief
Notice Of Objection Allowed In Full, $58,000 Reversed — US Pension Recipient, Lethbridge
Client: A Canadian resident receiving US pension income. Where: Lethbridge, Alberta. Engagement: 8 weeks, fixed fee.
Amount reversed$58,000
ObjectionAllowed in full
Account balanceNil
Case 2: the situation
A Canadian resident receiving US pension income in Lethbridge, Alberta had been reassessed for $58,000. 15 days were left on the objection deadline. The reassessment rested on dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability.
Case 2: what we did
We filed the objection inside the deadline with a complete submission rather than a placeholder. Alongside it, we filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely.
Case 2: the result
The appeals officer allowed the objection in full. $58,000 was reversed and the account returned to a nil balance.
Case Study 3 · Deadline rescue
Filed On Time From A Standing Start, $108,000 Penalty Avoided — US Citizen in Canada, Victoria
Client: A US citizen living in Canada. Where: Victoria, British Columbia. Engagement: 8 weeks, fixed fee.
Penalty avoided$108,000
Turnaround8 weeks
FiledOn time
Case 3: the situation
A US citizen living in Canada in Victoria, British Columbia came to us 8 weeks before its filing deadline. The file came with a US LLC taxed as a corporation in Canada, producing double tax on the same income. A late filing would have triggered a penalty of roughly $108,000 before interest.
Case 3: what we did
We worked backwards from the deadline. 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. We prioritised the items that actually gated the filing and deferred everything that did not.
Case 3: the result
The return was filed on time and complete. The $108,000 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.
Case Study 4 · Scaling without breaking
Second-Province Expansion Handled, $112,000 Of Cash Released — Arizona Snowbird, London
Client: A snowbird spending winters in Arizona. Where: London, Ontario. Engagement: 3 weeks, fixed fee.
Cash released$112,000
New registrationsComplete on day one
Compliance gapsNone
Case 4: the situation
Revenue at a snowbird spending winters in Arizona in London, Ontario was up sharply and cash was tighter than ever. Underneath it sat US tax paid but no foreign tax credit claimed on the Canadian return.
Case 4: what we did
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. Every new obligation was set up before it was triggered, not after. That covered registration, remittance frequency and provincial filing.
Case 4: the result
$112,000 of cash was released from the working capital cycle. The expansion completed with every registration and filing obligation covered from day one.
Client: A dual citizen with a US retirement account. Where: Winnipeg, Manitoba. Engagement: 5 weeks, fixed fee.
Overpayment refunded$14,000
Late remittances sinceZero
ScheduleAutomated
Case 5: the situation
Remittances at a dual citizen with a US retirement account in Winnipeg, Manitoba were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat winters spent in the United States with the day count kept casually and no residency position documented anywhere.
Case 5: what we did
We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. Then we moved the remittance dates into a scheduled process rather than a monthly decision.
Case 5: the result
Penalties stopped from the following remittance onwards, and $14,000 of overpaid instalments was refunded.
Case Study 6 · Planning that cut the bill
Remuneration Review Saved $27,000 Across Corporate And Personal Returns — Canadian on US Payroll, Toronto
Client: A Canadian with a US employer. Where: Toronto, Ontario. Engagement: 5 weeks, fixed fee.
Combined saving$27,000
ScopeCorporate + personal
Future yearsNo rework needed
Case 6: the situation
Nothing was wrong at a Canadian with a US employer in Toronto, Ontario. The filings were on time and accurate. What they were not was planned. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net had never been reviewed.
Case 6: what we did
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 ran the numbers across both the corporate and personal returns, so the saving was real rather than deferred into someone else's hands.
Case 6: the result
$27,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
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.
