6 worked Intercompany Pricing Policy 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 pricing policy work, not a specific client's file.
Case Study 1 · Records and systems rebuilt
Month-End Close Cut From 6 Weeks To 10 Days — Canadian on US Payroll, Ottawa
Client: A Canadian with a US employer. Where: Ottawa, Ontario. Engagement: 8 weeks, fixed fee.
Close time before6 weeks
Close time after10 days
Year-endReview, not rebuild
Case 1: the situation
The accounting file at a Canadian with a US employer in Ottawa, Ontario had a weak foundation. It was built on a departure year filed as a normal resident return with no deemed disposition reported. The year-end had taken 6 weeks each of the last three years.
Case 1: what we did
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. We also moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.
Case 1: 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 — US Branch Operator, Edmonton
Client: A Canadian corporation operating a US branch. Where: Edmonton, Alberta. Engagement: 11 weeks, fixed fee.
Amount reversed$115,000
ObjectionAllowed in full
Account balanceNil
Case 2: the situation
A Canadian corporation operating a US branch in Edmonton, Alberta had been reassessed for $115,000. 9 days were left on the objection deadline. The reassessment rested on a US LLC taxed as a corporation in Canada, producing double tax on the same income.
Case 2: what we did
We filed the objection inside the deadline with a complete submission rather than a placeholder. Alongside it, 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.
Case 2: 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 — US Pension Recipient, Mississauga
Client: A Canadian resident receiving US pension income. Where: Mississauga, Ontario. Engagement: 4 weeks, fixed fee.
Penalty avoided$59,000
Turnaround4 weeks
FiledOn time
Case 3: the situation
A Canadian resident receiving US pension income in Mississauga, Ontario came to us 4 weeks before its filing deadline. The file came with winters spent in the United States with the day count kept casually and no residency position documented anywhere. A late filing would have triggered a penalty of roughly $59,000 before interest.
Case 3: what we did
We worked backwards from the deadline. 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 prioritised the items that actually gated the filing and deferred everything that did not.
Case 3: 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 — US-Facing Canadian Corporation, 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
Case 4: the situation
A Canadian corporation with US customers in Vancouver, British Columbia was growing fast, with headcount reaching 77 in eighteen months. The back office had not kept up. Invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken was the first thing to break.
Case 4: what we did
We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. We built the compliance calendar for the size the business was becoming rather than the size it had been.
Case 4: 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.
Client: A dual citizen with a US retirement account. Where: Calgary, Alberta. Engagement: 11 weeks, fixed fee.
Overpayment refunded$92,000
Late remittances sinceZero
ScheduleAutomated
Case 5: the situation
Remittances at a dual citizen with a US retirement account in Calgary, Alberta were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat US tax paid but no foreign tax credit claimed on the Canadian return.
Case 5: what we did
We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. Then we moved the remittance dates into a scheduled process rather than a monthly decision.
Case 5: 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 — Inbound Assignee, Toronto
Client: An inbound transferee on assignment. Where: Toronto, Ontario. Engagement: 11 weeks, fixed fee.
Combined saving$52,000
ScopeCorporate + personal
Future yearsNo rework needed
Case 6: the situation
Nothing was wrong at an inbound transferee on assignment in Toronto, Ontario. The filings were on time and accurate. What they were not was planned. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net had never been reviewed.
Case 6: what we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. We ran the numbers across both the corporate and personal returns, so the saving was real rather than deferred into someone else's hands.
Case 6: the result
$52,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
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.
