Departure Tax Return Case Studies

6 Departure Tax Return 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 departure tax return work, not a general example.

Case Study 1 · Objection and relief

Notice Of Objection Allowed In Full, $87,000 Reversed — Shareholder of a US, Kelowna

Client: A shareholder of a US LLC  ·  Where: Kelowna, British Columbia  ·  Engagement: 4 weeks, fixed fee

Amount reversed$87,000
ObjectionAllowed in full
Account balanceNil

The situation

A shareholder of a US LLC in Kelowna, British Columbia had been reassessed for $87,000 and had 22 days left on the objection deadline. The reassessment rested on foreign accounts that had passed the $100,000 T1135 threshold three years earlier.

What we did

We filed the objection inside the deadline with a complete submission rather than a placeholder, and reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.

The result

The appeals officer allowed the objection in full. $87,000 was reversed and the account returned to a nil balance.

Case Study 2 · Deadline rescue

$117,000 Late-Filing Penalty Cancelled On Relief Application — Canadian Resident with a, Barrie

Client: A Canadian resident with a US rental property  ·  Where: Barrie, Ontario  ·  Engagement: 9 weeks, fixed fee

Penalty cancelled$117,000
Relief applicationGranted
ReturnAccepted as filed

The situation

A Canadian resident with a US rental property in Barrie, Ontario had already missed one deadline and was about to miss a second. Behind it sat US tax paid but no foreign tax credit claimed on the Canadian return, and a penalty of $117,000 was accruing.

What we did

We split the work into what had to happen before the deadline and what could follow it, then filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely.

The result

The outstanding return was accepted as filed, and the taxpayer relief application cancelled $117,000 of the penalty already assessed on the earlier year.

Case Study 3 · Records and systems rebuilt

Month-End Close Cut From 6 Weeks To 9 Days — US Citizen Living in, Moncton

Client: A US citizen living in Canada  ·  Where: Moncton, New Brunswick  ·  Engagement: 11 weeks, fixed fee

Close time before6 weeks
Close time after9 days
Year-endReview, not rebuild

The situation

The accounting file at a US citizen living in Canada in Moncton, New Brunswick was built on a departure year filed as a normal resident return with no deemed disposition reported. The year-end had taken 6 weeks each of the last three years.

What we did

We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward and moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.

The result

The file reconciles. Month-end closes in 9 days instead of 6 weeks, and the year-end is a review rather than a reconstruction.

Case Study 4 · Cash and remittance control

Remittance Schedule Corrected, $64,000 Refunded — Canadian Corporation with US, Windsor

Client: A Canadian corporation with US customers  ·  Where: Windsor, Ontario  ·  Engagement: 3 weeks, fixed fee

Overpayment refunded$64,000
Late remittances sinceZero
ScheduleAutomated

The situation

Remittances at a Canadian corporation with US customers in Windsor, Ontario were consistently late by a few days, which 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

We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, then moved the remittance dates into a scheduled process rather than a monthly decision.

The result

Penalties stopped from the following remittance onwards, and $64,000 of overpaid instalments was refunded.

Case Study 5 · Planning that cut the bill

$34,500 Cut From The Annual Tax Bill — Snowbird Spending Winters in, Victoria

Client: A snowbird spending winters in Arizona  ·  Where: Victoria, British Columbia  ·  Engagement: 8 weeks, fixed fee

First-year saving$34,500
RepeatsAnnually
Filing positionUnchanged in risk

The situation

A snowbird spending winters in Arizona in Victoria, British Columbia was compliant but paying more than it needed to. The prior year had been filed correctly and still left a US LLC taxed as a corporation in Canada, producing double tax on the same income on the table.

What we did

We modelled the current position against the alternatives before changing anything, then reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.

The result

The change saved $34,500 in the first year and repeats annually. Nothing about the filings became more aggressive; the position is simply the one the rules already allowed.

Case Study 6 · Scaling without breaking

Growth Handled Without A Missed Filing, $68,000 Freed — Non-Resident Owning Canadian Rental, Red Deer

Client: A non-resident owning Canadian rental property  ·  Where: Red Deer, Alberta  ·  Engagement: 3 weeks, fixed fee

Cash freed$68,000
Compliance failuresNone
ReportingMonthly

The situation

A non-resident owning Canadian rental property in Red Deer, Alberta was opening in a second province — different filing obligations, a different payroll regime, and foreign accounts that had passed the $100,000 T1135 threshold three years earlier already in the file.

What we did

We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely and put monthly reporting in place so the owner could see the cash effect of growth while there was still time to act on it.

The result

Growth was absorbed without a compliance failure. $68,000 of cash was released, and the monthly reporting now flags a problem while it is still small.

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.

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