6 Intercompany Pricing Policy 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 pricing policy work, not a general example.
Case Study 1 · Records and systems rebuilt
Month-End Close Cut From 6 Weeks To 10 Days — Dual Citizen with a, Ottawa
Client: A dual citizen with a US retirement account · Where: Ottawa, Ontario · Engagement: 8 weeks, fixed fee
Close time before6 weeks
Close time after10 days
Year-endReview, not rebuild
The situation
The accounting file at a dual citizen with a US retirement account in Ottawa, Ontario 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
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused and moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.
The result
The file reconciles. Month-end closes in 10 days instead of 6 weeks, and the year-end is a review rather than a reconstruction.
Case Study 2 · Objection and relief
Notice Of Objection Allowed In Full, $115,000 Reversed — Non-Resident Owning Canadian Rental, Edmonton
Client: A non-resident owning Canadian rental property · Where: Edmonton, Alberta · Engagement: 11 weeks, fixed fee
Amount reversed$115,000
ObjectionAllowed in full
Account balanceNil
The situation
A non-resident owning Canadian rental property in Edmonton, Alberta had been reassessed for $115,000 and had 9 days left on the objection deadline. The reassessment rested on foreign accounts that had passed the $100,000 T1135 threshold three years earlier.
What we did
We filed the objection inside the deadline with a complete submission rather than a placeholder, and filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund.
The result
The appeals officer allowed the objection in full. $115,000 was reversed and the account returned to a nil balance.
Case Study 3 · Deadline rescue
Filed On Time From A Standing Start, $59,000 Penalty Avoided — Snowbird Spending Winters in, Mississauga
Client: A snowbird spending winters in Arizona · Where: Mississauga, Ontario · Engagement: 4 weeks, fixed fee
Penalty avoided$59,000
Turnaround4 weeks
FiledOn time
The situation
A snowbird spending winters in Arizona in Mississauga, Ontario came to us 4 weeks before its filing deadline with US tax paid but no foreign tax credit claimed on the Canadian return. A late filing would have triggered a penalty of roughly $59,000 before interest.
What we did
We worked backwards from the deadline. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, prioritising the items that actually gated the filing and deferring everything that did not.
The result
The return was filed on time and complete. The $59,000 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.
Case Study 4 · Scaling without breaking
Scaled To 77 Staff With $30,500 Of Working Capital Freed — Canadian Corporation with US, Vancouver
Client: A Canadian corporation with US customers · Where: Vancouver, British Columbia · Engagement: 7 weeks, fixed fee
Headcount reached77
Working capital freed$30,500
Missed deadlinesZero
The situation
A Canadian corporation with US customers in Vancouver, British Columbia was growing fast — headcount to 77 in eighteen months — and the back office had not kept up. A departure year filed as a normal resident return with no deemed disposition reported was the first thing to break.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, and built the compliance calendar for the size the business was becoming rather than the size it had been.
The result
The business reached 77 staff with no missed remittance and no late filing. $30,500 of working capital was freed in the process.
Case Study 5 · Cash and remittance control
Remittance Schedule Corrected, $92,000 Refunded — US Citizen Living in, Calgary
Client: A US citizen living in Canada · Where: Calgary, Alberta · Engagement: 11 weeks, fixed fee
Overpayment refunded$92,000
Late remittances sinceZero
ScheduleAutomated
The situation
Remittances at a US citizen living in Canada in Calgary, Alberta were consistently late by a few days, which was enough to trigger penalties every quarter. Behind it sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
What we did
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused, then moved the remittance dates into a scheduled process rather than a monthly decision.
The result
Penalties stopped from the following remittance onwards, and $92,000 of overpaid instalments was refunded.
Case Study 6 · Planning that cut the bill
Remuneration Review Saved $52,000 Across Corporate And Personal Returns — Canadian Resident with a, Toronto
Client: A Canadian resident with a US rental property · Where: Toronto, Ontario · Engagement: 11 weeks, fixed fee
Combined saving$52,000
ScopeCorporate + personal
Future yearsNo rework needed
The situation
Nothing was wrong at a Canadian resident with a US rental property in Toronto, Ontario — the filings were on time and accurate. What they were not was planned. A US LLC taxed as a corporation in Canada, producing double tax on the same income 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
$52,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
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.
