6 worked Intercompany Guarantee Review 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 intercompany guarantee review work, not a specific client's file.
Case Study 1 · Records and systems rebuilt
11 Months Reconciled And $5,700 Of Input Tax Recovered — Canadian on US Payroll, Ottawa
Client: A Canadian with a US employer · Where: Ottawa, Ontario · Engagement: 4 weeks, fixed fee
Months reconciled11
Input tax recovered$5,700
Close time5 days
The situation — A Canadian with a US employer, Ottawa, Ontario
Nothing reconciled at a Canadian with a US employer in Ottawa, Ontario. Every filing started with 11 months of cleanup. The file was carrying a departure year filed as a normal resident return with no deemed disposition reported.
What we did for A Canadian with a US employer, Ottawa, Ontario
We rebuilt from source rather than correcting on top of the existing file. We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. Then we set the routine that keeps it clean.
The result — A Canadian with a US employer, Ottawa, Ontario
11 months reconciled to the bank. The close now takes 5 days, and $5,700 of previously unclaimable input tax was recovered in the process.
Case Study 2 · Sale and succession
Share Sale Restructured, $360,000 Less Tax On Closing — US Retirement Account Holder, Kitchener
Client: A dual citizen with a US retirement account · Where: Kitchener, Ontario · Engagement: 3 weeks, fixed fee
Tax saved on closing$360,000
PriceAs agreed
Post-closing adjustmentsNone
The situation — A dual citizen with a US retirement account, Kitchener, Ontario
A dual citizen with a US retirement account in Kitchener, Ontario was preparing to sell. Due diligence surfaced retained cash well above what the business needed to operate. That would have reduced the price or killed the deal outright.
What we did for A dual citizen with a US retirement account, Kitchener, Ontario
We cleaned up the historical file. 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. Then we prepared the due-diligence package the buyer's advisers actually asked for.
The result — A dual citizen with a US retirement account, Kitchener, Ontario
The deal closed at the agreed price. $360,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.
Case Study 3 · CRA review defended
$126,000 Reassessment Reduced To Nil On Review — Arizona Snowbird, Calgary
Client: A snowbird spending winters in Arizona · Where: Calgary, Alberta · Engagement: 11 weeks, fixed fee
Reassessment reduced toNil
Tax protected$126,000
Prior filingsUndisturbed
The situation — A snowbird spending winters in Arizona, Calgary, Alberta
A review notice arrived at a snowbird spending winters in Arizona in Calgary, Alberta, covering intercompany guarantee review for two tax years. The auditor's working position was an adjustment of $126,000. It was driven by winters spent in the United States with the day count kept casually and no residency position documented anywhere.
What we did for A snowbird spending winters in Arizona, Calgary, Alberta
Rather than negotiate, we rebuilt the record. 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 then submitted a point-by-point response that answered each proposed adjustment with the document behind it.
The result — A snowbird spending winters in Arizona, Calgary, Alberta
The auditor accepted the documented position and closed the review without adjustment, protecting $126,000 and leaving the prior filings undisturbed.
Case Study 4 · Planning that cut the bill
Remuneration Review Saved $33,000 Across Corporate And Personal Returns — US Citizen in Canada, London
Client: A US citizen living in Canada · Where: London, Ontario · Engagement: 11 weeks, fixed fee
Combined saving$33,000
ScopeCorporate + personal
Future yearsNo rework needed
The situation — A US citizen living in Canada, London, Ontario
Nothing was wrong at a US citizen living in Canada in London, Ontario. The filings were on time and accurate. What they were not was planned. Invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken had never been reviewed.
What we did for A US citizen living in Canada, London, Ontario
We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. 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 US citizen living in Canada, London, Ontario
$33,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
Case Study 5 · Scaling without breaking
Second-Province Expansion Handled, $111,000 Of Cash Released — US Pension Recipient, Kelowna
Client: A Canadian resident receiving US pension income · Where: Kelowna, British Columbia · Engagement: 9 weeks, fixed fee
Cash released$111,000
New registrationsComplete on day one
Compliance gapsNone
The situation — A Canadian resident receiving US pension income, Kelowna, British Columbia
Revenue at a Canadian resident receiving US pension income in Kelowna, British Columbia was up sharply and cash was tighter than ever. Underneath it sat US tax paid but no foreign tax credit claimed on the Canadian return.
What we did for A Canadian resident receiving US pension income, Kelowna, British Columbia
We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. Every new obligation was set up before it was triggered, not after. That covered registration, remittance frequency and provincial filing.
The result — A Canadian resident receiving US pension income, Kelowna, British Columbia
$111,000 of cash was released from the working capital cycle. The expansion completed with every registration and filing obligation covered from day one.
Case Study 6 · Objection and relief
Notice Of Objection Allowed In Full, $54,000 Reversed — Cross-Border Contractor, Hamilton
Client: A contractor working on both sides of the border · Where: Hamilton, Ontario · Engagement: 5 weeks, fixed fee
Amount reversed$54,000
ObjectionAllowed in full
Account balanceNil
The situation — A contractor working on both sides of the border, Hamilton, Ontario
A contractor working on both sides of the border in Hamilton, Ontario had been reassessed for $54,000. 23 days were left on the objection deadline. The reassessment rested on 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
What we did for A contractor working on both sides of the border, Hamilton, Ontario
We filed the objection inside the deadline with a complete submission rather than a placeholder. Alongside it, we filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely.
The result — A contractor working on both sides of the border, Hamilton, Ontario
The appeals officer allowed the objection in full. $54,000 was reversed and the account returned to a nil balance.
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.
