6 worked Cross-Border Retirement 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 cross-border retirement planning work, not a specific client's file.
Case Study 1 · Missed incentive claimed
Incentive Review Recovered $25,500 Across 7 Open Years — US Retirement Account Holder, Mississauga
Client: A dual citizen with a US retirement account. Where: Mississauga, Ontario. Engagement: 11 weeks, fixed fee.
Recovered$25,500
Open years claimed7
Ongoing trackingIn place
Case 1: the situation
An incentive review at a dual citizen with a US retirement account in Mississauga, Ontario started from a simple question: what has never been claimed? The answer ran to 7 years. It was driven by invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken.
Case 1: what we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
Case 1: the result
The credits produced $25,500 across the open years. The tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.
Case Study 2 · Objection and relief
Notice Of Objection Allowed In Full, $93,000 Reversed — Arizona Snowbird, Windsor
Client: A snowbird spending winters in Arizona. Where: Windsor, Ontario. Engagement: 4 weeks, fixed fee.
Amount reversed$93,000
ObjectionAllowed in full
Account balanceNil
Case 2: the situation
A snowbird spending winters in Arizona in Windsor, Ontario had been reassessed for $93,000. 7 days were left on the objection deadline. The reassessment rested on invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken.
Case 2: what we did
We filed the objection inside the deadline with a complete submission rather than a placeholder. Alongside it, we aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns.
Case 2: the result
The appeals officer allowed the objection in full. $93,000 was reversed and the account returned to a nil balance.
Case Study 3 · Structure rebuilt
Reorganisation Completed Tax-Deferred, $24,000 Saved Each Year — US Citizen in Canada, Halifax
Client: A US citizen living in Canada. Where: Halifax, Nova Scotia. Engagement: 11 weeks, fixed fee.
Annual saving$24,000
Tax on reorganisationDeferred
Elections filedOn time
Case 3: the situation
A US citizen living in Canada in Halifax, Nova Scotia had outgrown the structure it started with. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net was the immediate problem. The longer-term one was that the structure blocked the next step.
Case 3: what we did
We mapped the current structure and modelled the target. Then 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. The tax-deferred elections were filed on time and the supporting valuations documented.
Case 3: the result
The reorganisation completed without triggering tax, and the new structure saves approximately $24,000 a year while removing the exposure the old one carried.
Case Study 4 · Cash and remittance control
Remittance Schedule Corrected, $73,000 Refunded — US Pension Recipient, Toronto
Client: A Canadian resident receiving US pension income. Where: Toronto, Ontario. Engagement: 11 weeks, fixed fee.
Overpayment refunded$73,000
Late remittances sinceZero
ScheduleAutomated
Case 4: the situation
Remittances at a Canadian resident receiving US pension income in Toronto, Ontario were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability.
Case 4: what we did
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. Then we moved the remittance dates into a scheduled process rather than a monthly decision.
Case 4: the result
Penalties stopped from the following remittance onwards, and $73,000 of overpaid instalments was refunded.
Case Study 5 · Records and systems rebuilt
Books Rebuilt From Source, $19,500 In Unclaimed Input Tax Found — Cross-Border Contractor, Kitchener
Client: A contractor working on both sides of the border. Where: Kitchener, Ontario. Engagement: 10 weeks, fixed fee.
Unclaimed tax found$19,500
Records rebuilt13 months
ProcessDocumented
Case 5: the situation
A contractor working on both sides of the border in Kitchener, Ontario 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.
Case 5: what we did
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. We then documented the process so the work does not depend on any one person remembering how it was done.
Case 5: the result
Records rebuilt and reconciled, $19,500 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.
Case Study 6 · CRA review defended
$134,000 Proposed Adjustment Withdrawn In Full — US LLC Shareholder, Winnipeg
Client: A shareholder of a US LLC. Where: Winnipeg, Manitoba. Engagement: 5 weeks, fixed fee.
Adjustment withdrawn$134,000
File closed in5 weeks
Penalties assessedNone
Case 6: the situation
A shareholder of a US LLC in Winnipeg, Manitoba received a proposal letter opening a review of cross-border retirement planning. The CRA had identified winters spent in the United States with the day count kept casually and no residency position documented anywhere. It proposed an adjustment of $134,000, with 30 days to respond.
Case 6: what we did
We treated the response as an evidence exercise rather than an argument. We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. We then indexed every supporting document against the specific line the auditor had questioned.
Case 6: the result
The proposed adjustment was withdrawn in full — all $134,000 of it. The file closed in 5 weeks with no change to the assessed amounts and no penalty.
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.
