6 worked Immigrant Tax Return 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 immigrant tax return work, not a specific client's file.
Case Study 1 · Deadline rescue
$137,000 Late-Filing Penalty Cancelled On Relief Application — US Pension Recipient, Brampton
Client: A Canadian resident receiving US pension income · Where: Brampton, Ontario · Engagement: 6 weeks, fixed fee
Penalty cancelled$137,000
Relief applicationGranted
ReturnAccepted as filed
The situation — A Canadian resident receiving US pension income, Brampton, Ontario
A Canadian resident receiving US pension income in Brampton, Ontario had already missed one deadline and was about to miss a second. Behind it sat a departure year filed as a normal resident return with no deemed disposition reported. A penalty of $137,000 was accruing.
What we did for A Canadian resident receiving US pension income, Brampton, Ontario
We split the work into what had to happen before the deadline and what could follow it. Then we reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.
The result — A Canadian resident receiving US pension income, Brampton, Ontario
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $137,000 of the penalty already assessed on the earlier year.
Case Study 2 · Missed incentive claimed
Incentive Review Recovered $145,000 Across 7 Open Years — Cross-Border Contractor, Barrie
Client: A contractor working on both sides of the border · Where: Barrie, Ontario · Engagement: 3 weeks, fixed fee
Recovered$145,000
Open years claimed7
Ongoing trackingIn place
The situation — A contractor working on both sides of the border, Barrie, Ontario
An incentive review at a contractor working on both sides of the border in Barrie, Ontario started from a simple question: what has never been claimed? The answer ran to 7 years. It was driven by a US LLC taxed as a corporation in Canada, producing double tax on the same income.
What we did for A contractor working on both sides of the border, Barrie, Ontario
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result — A contractor working on both sides of the border, Barrie, Ontario
The credits produced $145,000 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 3 · Records and systems rebuilt
19 Months Reconciled And $13,000 Of Input Tax Recovered — US LLC Shareholder, Mississauga
Client: A shareholder of a US LLC · Where: Mississauga, Ontario · Engagement: 5 weeks, fixed fee
Months reconciled19
Input tax recovered$13,000
Close time7 days
The situation — A shareholder of a US LLC, Mississauga, Ontario
Nothing reconciled at a shareholder of a US LLC in Mississauga, Ontario. Every filing started with 19 months of cleanup. The file was carrying invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken.
What we did for A shareholder of a US LLC, Mississauga, Ontario
We rebuilt from source rather than correcting on top of the existing file. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. Then we set the routine that keeps it clean.
The result — A shareholder of a US LLC, Mississauga, Ontario
19 months reconciled to the bank. The close now takes 7 days, and $13,000 of previously unclaimable input tax was recovered in the process.
Case Study 4 · Cross-border exposure resolved
$28,500 Of Double Taxation Removed On Treaty Position — Canadian on US Payroll, Saskatoon
Client: A Canadian with a US employer · Where: Saskatoon, Saskatchewan · Engagement: 10 weeks, fixed fee
Double tax removed$28,500
DisclosureBrought current
Penalty exposureEliminated
The situation — A Canadian with a US employer, Saskatoon, Saskatchewan
A Canadian with a US employer in Saskatoon, Saskatchewan had US-side activity that the Canadian filings had never addressed. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net meant the same income was being taxed twice.
What we did for A Canadian with a US employer, Saskatoon, Saskatchewan
We established the residency and source position first. Then we filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. That way the Canadian and foreign filings finally told the same story.
The result — A Canadian with a US employer, Saskatoon, Saskatchewan
$28,500 of double taxation was removed, the disclosure obligations were brought current, and the penalty exposure was eliminated through the voluntary route.
Case Study 5 · Objection and relief
$118,000 Of Penalties And Interest Cancelled On Relief — US Retirement Account Holder, Victoria
Client: A dual citizen with a US retirement account · Where: Victoria, British Columbia · Engagement: 8 weeks, fixed fee
Penalties and interest cancelled$118,000
Relief groundsAccepted
AssessmentAdjusted to filed position
The situation — A dual citizen with a US retirement account, Victoria, British Columbia
An assessment of $118,000 landed at a dual citizen with a US retirement account in Victoria, British Columbia following a desk review. It turned on winters spent in the United States with the day count kept casually and no residency position documented anywhere. The auditor had not seen the records behind it.
What we did for A dual citizen with a US retirement account, Victoria, British Columbia
We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. We then set out the legislative basis for the position alongside the documents supporting it.
The result — A dual citizen with a US retirement account, Victoria, British Columbia
$118,000 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.
Case Study 6 · CRA review defended
$79,000 Proposed Adjustment Withdrawn In Full — Arizona Snowbird, Toronto
Client: A snowbird spending winters in Arizona · Where: Toronto, Ontario · Engagement: 10 weeks, fixed fee
Adjustment withdrawn$79,000
File closed in10 weeks
Penalties assessedNone
The situation — A snowbird spending winters in Arizona, Toronto, Ontario
A snowbird spending winters in Arizona in Toronto, Ontario received a proposal letter opening a review of immigrant tax return. The CRA had identified US tax paid but no foreign tax credit claimed on the Canadian return. It proposed an adjustment of $79,000, with 30 days to respond.
What we did for A snowbird spending winters in Arizona, Toronto, Ontario
We treated the response as an evidence exercise rather than an argument. We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. We then indexed every supporting document against the specific line the auditor had questioned.
The result — A snowbird spending winters in Arizona, Toronto, Ontario
The proposed adjustment was withdrawn in full — all $79,000 of it. The file closed in 10 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.
