6 Intercompany Loan Benchmarking tax and accounting engagements in full — what the client came to us with, what we did, and what it was worth. Each one is specific to intercompany loan benchmarking work, not a general example.
Case Study 1 · Scaling without breaking
Second-Province Expansion Handled, $82,000 Of Cash Released — Canadian Corporation with US, Windsor
Client: A Canadian corporation with US customers · Where: Windsor, Ontario · Engagement: 9 weeks, fixed fee
Cash released$82,000
New registrationsComplete on day one
Compliance gapsNone
The situation
Revenue at a Canadian corporation with US customers in Windsor, Ontario was up sharply and cash was tighter than ever. Underneath it sat a departure year filed as a normal resident return with no deemed disposition reported.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. Every new obligation — registration, remittance frequency, provincial filing — was set up before it was triggered, not after.
The result
$82,000 of cash was released from the working capital cycle, and the expansion completed with every registration and filing obligation covered from day one.
Case Study 2 · Cash and remittance control
Instalments Rebased, $126,000 Of Cash Returned To The Business — Shareholder of a US, Mississauga
Client: A shareholder of a US LLC · Where: Mississauga, Ontario · Engagement: 10 weeks, fixed fee
Cash returned$126,000
Instalment basisCurrent year
ReviewedQuarterly
The situation
A shareholder of a US LLC in Mississauga, Ontario was paying instalments calculated on a prior year that no longer reflected the business. US tax paid but no foreign tax credit claimed on the Canadian return was tying up $126,000 of cash.
What we did
We rebased the instalments on the current-year estimate rather than the prior-year default, and restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward.
The result
$126,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.
Case Study 3 · Planning that cut the bill
Remuneration Review Saved $15,500 Across Corporate And Personal Returns — Emigrant Who Left Canada, Burnaby
Client: An emigrant who left Canada mid-year · Where: Burnaby, British Columbia · Engagement: 5 weeks, fixed fee
Combined saving$15,500
ScopeCorporate + personal
Future yearsNo rework needed
The situation
Nothing was wrong at an emigrant who left Canada mid-year in Burnaby, British Columbia — the filings were on time and accurate. What they were not was planned. Foreign accounts that had passed the $100,000 T1135 threshold three years earlier had never been reviewed.
What we did
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, and 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
$15,500 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
Client: A snowbird spending winters in Arizona · Where: Kelowna, British Columbia · Engagement: 8 weeks, fixed fee
Amount recovered$143,000
Reporting statusCurrent
Annual effortHours, not weeks
The situation
Foreign holdings at a snowbird spending winters in Arizona in Kelowna, British Columbia 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
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused, claiming the treaty relief and foreign tax credits on the Canadian return and correcting the disclosure position for the open years.
The result
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 5 · CRA review defended
Audit Defence Closed In 7 Weeks, $80,000 Cleared — Canadian Resident with a, Winnipeg
Client: A Canadian resident with a US rental property · Where: Winnipeg, Manitoba · Engagement: 7 weeks, fixed fee
Proposed tax cleared$80,000
Review duration7 weeks
OutcomeNo change
The situation
A Canadian resident with a US rental property in Winnipeg, Manitoba was selected for review after 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net showed up in the CRA's automated matching. The proposed adjustment on intercompany loan benchmarking came to $80,000.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. Every figure in the response traced to a source record the auditor could verify without asking a second question.
The result
The review closed with no change. $80,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.
Case Study 6 · Missed incentive claimed
$106,000 Credit Claim Filed And Accepted Without Adjustment — Canadian with a US, Kitchener
Client: A Canadian with a US employer · Where: Kitchener, Ontario · Engagement: 10 weeks, fixed fee
Claim value$106,000
AcceptedWithout adjustment
RepeatableAnnually
The situation
A Canadian with a US employer in Kitchener, Ontario assumed the credits did not apply to a business its size. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net meant they had applied all along.
What we did
We identified the qualifying activity, built the documentation to support it, and restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward.
The result
$106,000 recovered. Because the eligibility analysis is on file, the same claim can be repeated each year with a fraction of the effort.
Reviewed for the 2025 tax year by Udit Gupta, Certified Tax Accountant. Figures describe representative engagements of this type; outcomes depend on your own facts. Client names and identifying details are omitted for confidentiality.
