FBAR Filing Assistance Case Studies

6 worked FBAR Filing Assistance 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 fbar filing assistance work, not a specific client's file.

Case Study 1 · Backlog brought current

Collections Halted And $122,000 Cut From A 4-Year Backlog — Inbound Assignee, Burnaby

Client: An inbound transferee on assignment  ·  Where: Burnaby, British Columbia  ·  Engagement: 7 weeks, fixed fee

Balance reduced by$122,000
Backlog cleared4 years
CollectionsHalted

The situation — An inbound transferee on assignment, Burnaby, British Columbia

By the time an inbound transferee on assignment in Burnaby, British Columbia called, 4 years were outstanding. The CRA had assessed on estimates. Underneath it sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.

What we did for An inbound transferee on assignment, Burnaby, British Columbia

We reconstructed the records year by year. We 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 — An inbound transferee on assignment, Burnaby, British Columbia

The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $122,000, and a relief application addressed part of the accumulated interest.

Case Study 2 · Records and systems rebuilt

Month-End Close Cut From 6 Weeks To 4 Days — US Rental Owner, Edmonton

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

Close time before6 weeks
Close time after4 days
Year-endReview, not rebuild

The situation — A Canadian resident with a US rental property, Edmonton, Alberta

The accounting file at a Canadian resident with a US rental property in Edmonton, Alberta had a weak foundation. It was built on a US LLC taxed as a corporation in Canada, producing double tax on the same income. The year-end had taken 6 weeks each of the last three years.

What we did for A Canadian resident with a US rental property, Edmonton, Alberta

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 moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.

The result — A Canadian resident with a US rental property, Edmonton, Alberta

The file reconciles. Month-end closes in 4 days instead of 6 weeks, and the year-end is a review rather than a reconstruction.

Case Study 3 · Cash and remittance control

Instalments Rebased, $24,500 Of Cash Returned To The Business — Mid-Year Emigrant, Barrie

Client: An emigrant who left Canada mid-year  ·  Where: Barrie, Ontario  ·  Engagement: 4 weeks, fixed fee

Cash returned$24,500
Instalment basisCurrent year
ReviewedQuarterly

The situation — An emigrant who left Canada mid-year, Barrie, Ontario

An emigrant who left Canada mid-year in Barrie, Ontario was paying instalments calculated on a prior year. That year no longer reflected the business. Foreign accounts that had passed the $100,000 T1135 threshold three years earlier was tying up $24,500 of cash.

What we did for An emigrant who left Canada mid-year, Barrie, Ontario

We rebased the instalments on the current-year estimate rather than the prior-year default. Alongside that, 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 — An emigrant who left Canada mid-year, Barrie, Ontario

$24,500 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.

Case Study 4 · Missed incentive claimed

$22,000 Credit Claim Filed And Accepted Without Adjustment — Florida Property Owner, Brampton

Client: A family with a Florida vacation property  ·  Where: Brampton, Ontario  ·  Engagement: 10 weeks, fixed fee

Claim value$22,000
AcceptedWithout adjustment
RepeatableAnnually

The situation — A family with a Florida vacation property, Brampton, Ontario

A family with a Florida vacation property in Brampton, Ontario assumed the credits did not apply to a business its size. A departure year filed as a normal resident return with no deemed disposition reported meant they had applied all along.

What we did for A family with a Florida vacation property, Brampton, Ontario

We identified the qualifying activity and built the documentation to support it. Then we filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely.

The result — A family with a Florida vacation property, Brampton, Ontario

$22,000 recovered. Because the eligibility analysis is on file, the same claim can be repeated each year with a fraction of the effort.

Case Study 5 · Sale and succession

Share Sale Restructured, $245,000 Less Tax On Closing — Non-Resident Landlord, Ottawa

Client: A non-resident owning Canadian rental property  ·  Where: Ottawa, Ontario  ·  Engagement: 7 weeks, fixed fee

Tax saved on closing$245,000
PriceAs agreed
Post-closing adjustmentsNone

The situation — A non-resident owning Canadian rental property, Ottawa, Ontario

A non-resident owning Canadian rental property in Ottawa, Ontario was preparing to sell. Due diligence surfaced no valuation on file to support the price the parties had agreed. That would have reduced the price or killed the deal outright.

What we did for A non-resident owning Canadian rental property, Ottawa, Ontario

We cleaned up the historical file. We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. Then we prepared the due-diligence package the buyer's advisers actually asked for.

The result — A non-resident owning Canadian rental property, Ottawa, Ontario

The deal closed at the agreed price. $245,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.

Case Study 6 · Deadline rescue

5-Week Turnaround Beat The Deadline And Saved $126,000 — US Branch Operator, Kelowna

Client: A Canadian corporation operating a US branch  ·  Where: Kelowna, British Columbia  ·  Engagement: 5 weeks, fixed fee

Late-filing penalty avoided$126,000
Filed with17 days to spare
Next yearPapers ready

The situation — A Canadian corporation operating a US branch, Kelowna, British Columbia

A Canadian corporation operating a US branch in Kelowna, British Columbia was weeks away from the deadline for FBAR filing assistance. Behind that sat invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken. The exposure if the date slipped was around $126,000.

What we did for A Canadian corporation operating a US branch, Kelowna, British Columbia

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 filing went in complete rather than provisional, so there was no amended return to follow.

The result — A Canadian corporation operating a US branch, Kelowna, British Columbia

Filed with 17 days to spare. $126,000 in late-filing penalties avoided, and the working papers are ready for the following year.

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 — Businesses · Income Tax Act (Justice Laws Website)

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