6 Cross-Border Real Estate Tax and accounting engagements in full — what the client came to us with, what we did, and what it was worth. Each one is specific to cross-border real estate tax work, not a general example.
Case Study 1 · CRA review defended
$91,000 Proposed Adjustment Withdrawn In Full — Snowbird Spending Winters in, London
Client: A snowbird spending winters in Arizona · Where: London, Ontario · Engagement: 4 weeks, fixed fee
Adjustment withdrawn$91,000
File closed in4 weeks
Penalties assessedNone
The situation
A snowbird spending winters in Arizona in London, Ontario received a proposal letter opening a review of cross-border real estate tax. The CRA had identified US tax paid but no foreign tax credit claimed on the Canadian return and proposed an adjustment of $91,000, with 30 days to respond.
What we did
We treated the response as an evidence exercise rather than an argument. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, then indexed every supporting document against the specific line the auditor had questioned.
The result
The proposed adjustment was withdrawn in full — all $91,000 of it. The file closed in 4 weeks with no change to the assessed amounts and no penalty.
Case Study 2 · Cross-border exposure resolved
Foreign Reporting Brought Current, $72,000 Recovered — Shareholder of a US, Calgary
Client: A shareholder of a US LLC · Where: Calgary, Alberta · Engagement: 5 weeks, fixed fee
Amount recovered$72,000
Reporting statusCurrent
Annual effortHours, not weeks
The situation
Foreign holdings at a shareholder of a US LLC in Calgary, Alberta had passed the reporting threshold without anyone noticing. Behind the disclosure problem sat a US LLC taxed as a corporation in Canada, producing double tax on the same income.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, claiming the treaty relief and foreign tax credits on the Canadian return and correcting the disclosure position for the open years.
The result
The treaty position was accepted and $72,000 was recovered. Reporting is now current and the annual process takes hours rather than weeks.
Case Study 3 · Missed incentive claimed
$51,000 In Credits Claimed That Prior Filings Had Missed — Dual Citizen with a, Kitchener
Client: A dual citizen with a US retirement account · Where: Kitchener, Ontario · Engagement: 5 weeks, fixed fee
Credits claimed$51,000
Years adjusted7
Review outcomeNo adjustment
The situation
A dual citizen with a US retirement account in Kitchener, Ontario had been filing for 7 years without ever claiming the incentives its activity qualified for. Behind that sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
What we did
We tested each activity against the eligibility criteria rather than the description on the invoice, then reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.
The result
$51,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 4 · Backlog brought current
Collections Halted And $15,000 Cut From A 6-Year Backlog — US Citizen Living in, Ottawa
Client: A US citizen living in Canada · Where: Ottawa, Ontario · Engagement: 10 weeks, fixed fee
Balance reduced by$15,000
Backlog cleared6 years
CollectionsHalted
The situation
By the time a US citizen living in Canada in Ottawa, Ontario called, 6 years were outstanding and the CRA had assessed on estimates. Underneath it sat foreign accounts that had passed the $100,000 T1135 threshold three years earlier.
What we did
We reconstructed the records year by year and filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. Each filing replaced an arbitrary assessment with a real one.
The result
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $15,000, and a relief application addressed part of the accumulated interest.
Case Study 5 · Sale and succession
Share Sale Restructured, $275,000 Less Tax On Closing — Canadian with a US, Moncton
Client: A Canadian with a US employer · Where: Moncton, New Brunswick · Engagement: 4 weeks, fixed fee
Tax saved on closing$275,000
PriceAs agreed
Post-closing adjustmentsNone
The situation
A Canadian with a US employer in Moncton, New Brunswick was preparing to sell. Due diligence surfaced a minute book with no resolutions behind a decade of dividends, which would have reduced the price or killed the deal outright.
What we did
We cleaned up the historical file, restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, and prepared the due-diligence package the buyer's advisers actually asked for.
The result
The deal closed at the agreed price. $275,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.
Case Study 6 · Structure rebuilt
Corporate Structure Rebuilt For $62,000 Of Annual Savings — Non-Resident Owning Canadian Rental, Halifax
Client: A non-resident owning Canadian rental property · Where: Halifax, Nova Scotia · Engagement: 6 weeks, fixed fee
Saving per year$62,000
DocumentationComplete
Transfer basisRollover
The situation
The structure at a non-resident owning Canadian rental property in Halifax, Nova Scotia had been set up years earlier for a business that no longer existed, and US tax paid but no foreign tax credit claimed on the Canadian return had become expensive.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result
$62,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Reviewed for the 2025 tax year by Udit Gupta, Certified Tax Accountant. Figures describe representative engagements of this type; outcomes depend on your own facts. Client names and identifying details are omitted for confidentiality.
