Expat Tax Services Case Studies

6 worked Expat Tax Services 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 expat tax services work, not a specific client's file.

Case Study 1 · Cross-border exposure resolved

Foreign Reporting Brought Current, $143,000 Recovered — Arizona Snowbird, Moncton

Client: A snowbird spending winters in Arizona  ·  Where: Moncton, New Brunswick  ·  Engagement: 8 weeks, fixed fee

Amount recovered$143,000
Reporting statusCurrent
Annual effortHours, not weeks

The situation — A snowbird spending winters in Arizona, Moncton, New Brunswick

Foreign holdings at a snowbird spending winters in Arizona in Moncton, New Brunswick 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 for A snowbird spending winters in Arizona, Moncton, New Brunswick

We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We claimed the treaty relief and foreign tax credits on the Canadian return and corrected the disclosure position for the open years.

The result — A snowbird spending winters in Arizona, Moncton, New Brunswick

The treaty position was accepted and $143,000 was recovered. Reporting is now current and the annual process takes hours rather than weeks.

Case Study 2 · Objection and relief

Notice Of Objection Allowed In Full, $67,000 Reversed — Cross-Border Contractor, London

Client: A contractor working on both sides of the border  ·  Where: London, Ontario  ·  Engagement: 8 weeks, fixed fee

Amount reversed$67,000
ObjectionAllowed in full
Account balanceNil

The situation — A contractor working on both sides of the border, London, Ontario

A contractor working on both sides of the border in London, Ontario had been reassessed for $67,000. 19 days were left on the objection deadline. The reassessment rested on a departure year filed as a normal resident return with no deemed disposition reported.

What we did for A contractor working on both sides of the border, London, Ontario

We filed the objection inside the deadline with a complete submission rather than a placeholder. Alongside it, 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 result — A contractor working on both sides of the border, London, Ontario

The appeals officer allowed the objection in full. $67,000 was reversed and the account returned to a nil balance.

Case Study 3 · CRA review defended

$78,000 Proposed Adjustment Withdrawn In Full — US Retirement Account Holder, Mississauga

Client: A dual citizen with a US retirement account  ·  Where: Mississauga, Ontario  ·  Engagement: 11 weeks, fixed fee

Adjustment withdrawn$78,000
File closed in11 weeks
Penalties assessedNone

The situation — A dual citizen with a US retirement account, Mississauga, Ontario

A dual citizen with a US retirement account in Mississauga, Ontario received a proposal letter opening a review of expat tax services. The CRA had identified invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken. It proposed an adjustment of $78,000, with 30 days to respond.

What we did for A dual citizen with a US retirement account, Mississauga, Ontario

We treated the response as an evidence exercise rather than an argument. We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. We then indexed every supporting document against the specific line the auditor had questioned.

The result — A dual citizen with a US retirement account, Mississauga, Ontario

The proposed adjustment was withdrawn in full — all $78,000 of it. The file closed in 11 weeks with no change to the assessed amounts and no penalty.

Case Study 4 · Deadline rescue

$120,000 Late-Filing Penalty Cancelled On Relief Application — US Pension Recipient, Barrie

Client: A Canadian resident receiving US pension income  ·  Where: Barrie, Ontario  ·  Engagement: 9 weeks, fixed fee

Penalty cancelled$120,000
Relief applicationGranted
ReturnAccepted as filed

The situation — A Canadian resident receiving US pension income, Barrie, Ontario

A Canadian resident receiving US pension income in Barrie, Ontario had already missed one deadline and was about to miss a second. Behind it sat winters spent in the United States with the day count kept casually and no residency position documented anywhere. A penalty of $120,000 was accruing.

What we did for A Canadian resident receiving US pension income, Barrie, Ontario

We split the work into what had to happen before the deadline and what could follow it. Then we reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked.

The result — A Canadian resident receiving US pension income, Barrie, Ontario

The outstanding return was accepted as filed, and the taxpayer relief application cancelled $120,000 of the penalty already assessed on the earlier year.

Case Study 5 · Missed incentive claimed

Incentive Review Recovered $110,000 Across 5 Open Years — Canadian on US Payroll, Burnaby

Client: A Canadian with a US employer  ·  Where: Burnaby, British Columbia  ·  Engagement: 9 weeks, fixed fee

Recovered$110,000
Open years claimed5
Ongoing trackingIn place

The situation — A Canadian with a US employer, Burnaby, British Columbia

An incentive review at a Canadian with a US employer in Burnaby, British Columbia started from a simple question: what has never been claimed? The answer ran to 5 years. It was driven by dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability.

What we did for A Canadian with a US employer, Burnaby, British Columbia

We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.

The result — A Canadian with a US employer, Burnaby, British Columbia

The credits produced $110,000 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 6 · Records and systems rebuilt

18 Months Reconciled And $18,000 Of Input Tax Recovered — US Citizen in Canada, Edmonton

Client: A US citizen living in Canada  ·  Where: Edmonton, Alberta  ·  Engagement: 10 weeks, fixed fee

Months reconciled18
Input tax recovered$18,000
Close time9 days

The situation — A US citizen living in Canada, Edmonton, Alberta

Nothing reconciled at a US citizen living in Canada in Edmonton, Alberta. Every filing started with 18 months of cleanup. The file was carrying US tax paid but no foreign tax credit claimed on the Canadian return.

What we did for A US citizen living in Canada, Edmonton, Alberta

We rebuilt from source rather than correcting on top of the existing file. We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. Then we set the routine that keeps it clean.

The result — A US citizen living in Canada, Edmonton, Alberta

18 months reconciled to the bank. The close now takes 9 days, and $18,000 of previously unclaimable input tax was recovered in the process.

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.

Sources. CRA — International and non-resident taxes · Income Tax Act (Justice Laws Website)

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