6 worked Foreign Tax Credit 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 foreign tax credit planning work, not a specific client's file.
Case Study 1 · Planning that cut the bill
Remuneration Review Saved $62,000 Across Corporate And Personal Returns — Non-Resident Landlord, Regina
Client: A non-resident owning Canadian rental property · Where: Regina, Saskatchewan · Engagement: 9 weeks, fixed fee
Combined saving$62,000
ScopeCorporate + personal
Future yearsNo rework needed
The situation — A non-resident owning Canadian rental property, Regina, Saskatchewan
Nothing was wrong at a non-resident owning Canadian rental property in Regina, Saskatchewan. The filings were on time and accurate. What they were not was planned. US tax paid but no foreign tax credit claimed on the Canadian return had never been reviewed.
What we did for A non-resident owning Canadian rental property, Regina, Saskatchewan
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 ran the numbers across both the corporate and personal returns, so the saving was real rather than deferred into someone else's hands.
The result — A non-resident owning Canadian rental property, Regina, Saskatchewan
$62,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
Case Study 2 · Cross-border exposure resolved
$89,000 Of Excess Withholding Refunded On Election — US Citizen in Canada, Calgary
Client: A US citizen living in Canada · Where: Calgary, Alberta · Engagement: 10 weeks, fixed fee
Withholding refunded$89,000
ElectionFiled and accepted
Cross-border reportingConsistent
The situation — A US citizen living in Canada, Calgary, Alberta
A US citizen living in Canada in Calgary, Alberta was paying tax in two countries on one stream of income. Winters spent in the United States with the day count kept casually and no residency position documented anywhere had never been reviewed against the treaty.
What we did for A US citizen living in Canada, Calgary, Alberta
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We also coordinated the timing so the credit claimed in Canada matched the tax actually paid abroad.
The result — A US citizen living in Canada, Calgary, Alberta
$89,000 of excess withholding was refunded and the exposure closed. Both sides of the border now report consistently, which is what keeps the credit claimable.
Case Study 3 · Backlog brought current
7 Years Filed, $43,000 Removed From The Assessed Balance — Florida Property Owner, Burnaby
Client: A family with a Florida vacation property · Where: Burnaby, British Columbia · Engagement: 8 weeks, fixed fee
Years filed7
Assessed balance removed$43,000
CollectionsStopped
The situation — A family with a Florida vacation property, Burnaby, British Columbia
A family with a Florida vacation property in Burnaby, British Columbia had not filed for 7 years. The CRA had issued arbitrary assessments. The business was carrying 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. That came on top of a growing interest balance.
What we did for A family with a Florida vacation property, Burnaby, British Columbia
We started with the oldest year and worked forward so each year's closing balances fed the next. We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. We filed the years in sequence rather than all at once.
The result — A family with a Florida vacation property, Burnaby, British Columbia
Every year is now filed and assessed on actual figures. The notional assessments were vacated and $43,000 of the estimated balance came off, with a payment arrangement covering the rest.
Case Study 4 · Records and systems rebuilt
Books Rebuilt From Source, $17,500 In Unclaimed Input Tax Found — US LLC Shareholder, Lethbridge
Client: A shareholder of a US LLC · Where: Lethbridge, Alberta · Engagement: 10 weeks, fixed fee
Unclaimed tax found$17,500
Records rebuilt19 months
ProcessDocumented
The situation — A shareholder of a US LLC, Lethbridge, Alberta
A shareholder of a US LLC in Lethbridge, Alberta could not answer basic questions about its own numbers. Invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken sat between the bank statements and the ledger.
What we did for A shareholder of a US LLC, Lethbridge, Alberta
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. We then documented the process so the work does not depend on any one person remembering how it was done.
The result — A shareholder of a US LLC, Lethbridge, Alberta
Records rebuilt and reconciled, $17,500 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.
Case Study 5 · Cash and remittance control
Instalments Rebased, $100,000 Of Cash Returned To The Business — Mid-Year Emigrant, Saskatoon
Client: An emigrant who left Canada mid-year · Where: Saskatoon, Saskatchewan · Engagement: 8 weeks, fixed fee
Cash returned$100,000
Instalment basisCurrent year
ReviewedQuarterly
The situation — An emigrant who left Canada mid-year, Saskatoon, Saskatchewan
An emigrant who left Canada mid-year in Saskatoon, Saskatchewan 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 $100,000 of cash.
What we did for An emigrant who left Canada mid-year, Saskatoon, Saskatchewan
We rebased the instalments on the current-year estimate rather than the prior-year default. Alongside that, we filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely.
The result — An emigrant who left Canada mid-year, Saskatoon, Saskatchewan
$100,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.
Case Study 6 · Missed incentive claimed
Incentive Review Recovered $136,000 Across 7 Open Years — Arizona Snowbird, Kelowna
Client: A snowbird spending winters in Arizona · Where: Kelowna, British Columbia · Engagement: 5 weeks, fixed fee
Recovered$136,000
Open years claimed7
Ongoing trackingIn place
The situation — A snowbird spending winters in Arizona, Kelowna, British Columbia
An incentive review at a snowbird spending winters in Arizona in Kelowna, British Columbia started from a simple question: what has never been claimed? The answer ran to 7 years. It was driven by a departure year filed as a normal resident return with no deemed disposition reported.
What we did for A snowbird spending winters in Arizona, 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. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result — A snowbird spending winters in Arizona, Kelowna, British Columbia
The credits produced $136,000 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.
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.
