6 worked Cross-Border Personal Tax 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 cross-border personal tax work, not a specific client's file.
Case Study 1 · CRA review defended
$62,000 Reassessment Reduced To Nil On Review — Florida Property Owner, Saskatoon
Client: A family with a Florida vacation property · Where: Saskatoon, Saskatchewan · Engagement: 6 weeks, fixed fee
Reassessment reduced toNil
Tax protected$62,000
Prior filingsUndisturbed
The situation — A family with a Florida vacation property, Saskatoon, Saskatchewan
A review notice arrived at a family with a Florida vacation property in Saskatoon, Saskatchewan, covering cross-border personal tax for two tax years. The auditor's working position was an adjustment of $62,000. It was driven by foreign accounts that had passed the $100,000 T1135 threshold three years earlier.
What we did for A family with a Florida vacation property, Saskatoon, Saskatchewan
Rather than negotiate, we rebuilt the record. We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. We then submitted a point-by-point response that answered each proposed adjustment with the document behind it.
The result — A family with a Florida vacation property, Saskatoon, Saskatchewan
The auditor accepted the documented position and closed the review without adjustment, protecting $62,000 and leaving the prior filings undisturbed.
Case Study 2 · Cross-border exposure resolved
$111,000 Of Double Taxation Removed On Treaty Position — Canadian on US Payroll, Surrey
Client: A Canadian with a US employer · Where: Surrey, British Columbia · Engagement: 11 weeks, fixed fee
Double tax removed$111,000
DisclosureBrought current
Penalty exposureEliminated
The situation — A Canadian with a US employer, Surrey, British Columbia
A Canadian with a US employer in Surrey, British Columbia had US-side activity that the Canadian filings had never addressed. US tax paid but no foreign tax credit claimed on the Canadian return meant the same income was being taxed twice.
What we did for A Canadian with a US employer, Surrey, British Columbia
We established the residency and source position first. Then we reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. That way the Canadian and foreign filings finally told the same story.
The result — A Canadian with a US employer, Surrey, British Columbia
$111,000 of double taxation was removed, the disclosure obligations were brought current, and the penalty exposure was eliminated through the voluntary route.
Client: A Canadian corporation with US customers · Where: Winnipeg, Manitoba · Engagement: 9 weeks, fixed fee
Annual saving$37,500
ReorganisationTax-neutral
StructureMatches operations
The situation — A Canadian corporation with US customers, Winnipeg, Manitoba
The structure at a Canadian corporation with US customers in Winnipeg, Manitoba needed fixing. The file was carrying a US LLC taxed as a corporation in Canada, producing double tax on the same income. Every option for fixing it ran through a reorganisation that had to be done without triggering tax.
What we did for A Canadian corporation with US customers, Winnipeg, Manitoba
We worked with the client's lawyer. Together, 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 also prepared the elections, resolutions and valuations the structure needed to stand up.
The result — A Canadian corporation with US customers, Winnipeg, Manitoba
The structure now matches the business. Annual saving of $37,500, and the reorganisation itself was tax-neutral.
Client: A contractor working on both sides of the border · Where: Edmonton, Alberta · Engagement: 10 weeks, fixed fee
Penalty cancelled$138,000
Relief applicationGranted
ReturnAccepted as filed
The situation — A contractor working on both sides of the border, Edmonton, Alberta
A contractor working on both sides of the border in Edmonton, Alberta had already missed one deadline and was about to miss a second. Behind it sat invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken. A penalty of $138,000 was accruing.
What we did for A contractor working on both sides of the border, Edmonton, Alberta
We split the work into what had to happen before the deadline and what could follow it. Then we filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund.
The result — A contractor working on both sides of the border, Edmonton, Alberta
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $138,000 of the penalty already assessed on the earlier year.
Case Study 5 · Cash and remittance control
Remittance Schedule Corrected, $50,000 Refunded — Mid-Year Emigrant, Vancouver
Client: An emigrant who left Canada mid-year · Where: Vancouver, British Columbia · Engagement: 5 weeks, fixed fee
Overpayment refunded$50,000
Late remittances sinceZero
ScheduleAutomated
The situation — An emigrant who left Canada mid-year, Vancouver, British Columbia
Remittances at an emigrant who left Canada mid-year in Vancouver, British Columbia were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
What we did for An emigrant who left Canada mid-year, Vancouver, British Columbia
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. Then we moved the remittance dates into a scheduled process rather than a monthly decision.
The result — An emigrant who left Canada mid-year, Vancouver, British Columbia
Penalties stopped from the following remittance onwards, and $50,000 of overpaid instalments was refunded.
Case Study 6 · Scaling without breaking
Growth Handled Without A Missed Filing, $58,000 Freed — US Citizen in Canada, Toronto
Client: A US citizen living in Canada · Where: Toronto, Ontario · Engagement: 7 weeks, fixed fee
Cash freed$58,000
Compliance failuresNone
ReportingMonthly
The situation — A US citizen living in Canada, Toronto, Ontario
A US citizen living in Canada in Toronto, Ontario was opening in a second province. That meant different filing obligations and a different payroll regime. Dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability already sat in the file.
What we did for A US citizen living in Canada, Toronto, Ontario
We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. We then put monthly reporting in place. That let the owner see the cash effect of growth while there was still time to act on it.
The result — A US citizen living in Canada, Toronto, Ontario
Growth was absorbed without a compliance failure. $58,000 of cash was released, and the monthly reporting now flags a problem while it is still small.
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.
