6 Intercompany Transaction Review 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 transaction review work, not a general example.
Case Study 1 · CRA review defended
$105,000 Reassessment Reduced To Nil On Review — Snowbird Spending Winters in, London
Client: A snowbird spending winters in Arizona · Where: London, Ontario · Engagement: 3 weeks, fixed fee
Reassessment reduced toNil
Tax protected$105,000
Prior filingsUndisturbed
The situation
A review notice arrived at a snowbird spending winters in Arizona in London, Ontario covering intercompany transaction review for two tax years. The auditor's working position was an adjustment of $105,000, driven by US tax paid but no foreign tax credit claimed on the Canadian return.
What we did
Rather than negotiate, we rebuilt the record. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward and submitted a point-by-point response that answered each proposed adjustment with the document behind it.
The result
The auditor accepted the documented position and closed the review without adjustment, protecting $105,000 and leaving the prior filings undisturbed.
Case Study 2 · Sale and succession
Intergenerational Transfer Completed With $580,000 Deferred — Shareholder of a US, Windsor
Client: A shareholder of a US LLC · Where: Windsor, Ontario · Engagement: 8 weeks, fixed fee
Tax deferred$580,000
TransferCompleted
RecordsReview-ready
The situation
A generational transfer at a shareholder of a US LLC in Windsor, Ontario had been discussed for years without a plan. A shareholder loan balance that would have been picked up as income on closing meant the transfer as contemplated would have been fully taxable.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, sequencing the steps so each one was complete and documented before the next depended on it.
The result
$580,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
Case Study 3 · Records and systems rebuilt
Month-End Close Cut From 12 Weeks To 5 Days — Dual Citizen with a, Calgary
Client: A dual citizen with a US retirement account · Where: Calgary, Alberta · Engagement: 5 weeks, fixed fee
Close time before12 weeks
Close time after5 days
Year-endReview, not rebuild
The situation
The accounting file at a dual citizen with a US retirement account in Calgary, Alberta was built on a departure year filed as a normal resident return with no deemed disposition reported. The year-end had taken 12 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 5 days instead of 12 weeks, and the year-end is a review rather than a reconstruction.
Case Study 4 · Planning that cut the bill
$28,000 Cut From The Annual Tax Bill — US Citizen Living in, Surrey
Client: A US citizen living in Canada · Where: Surrey, British Columbia · Engagement: 7 weeks, fixed fee
First-year saving$28,000
RepeatsAnnually
Filing positionUnchanged in risk
The situation
A US citizen living in Canada in Surrey, British Columbia was compliant but paying more than it needed to. The prior year had been filed correctly and still left foreign accounts that had passed the $100,000 T1135 threshold three years earlier on the table.
What we did
We modelled the current position against the alternatives before changing anything, then filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund.
The result
The change saved $28,000 in the first year and repeats annually. Nothing about the filings became more aggressive; the position is simply the one the rules already allowed.
Case Study 5 · Backlog brought current
5 Years Filed, $137,000 Removed From The Assessed Balance — Canadian with a US, Kitchener
Client: A Canadian with a US employer · Where: Kitchener, Ontario · Engagement: 10 weeks, fixed fee
Years filed5
Assessed balance removed$137,000
CollectionsStopped
The situation
A Canadian with a US employer in Kitchener, Ontario had not filed for 5 years. The CRA had issued arbitrary assessments, and the business was carrying 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net on top of a growing interest balance.
What we did
We started with the oldest year and worked forward so each year's closing balances fed the next. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, filing the years in sequence rather than all at once.
The result
Every year is now filed and assessed on actual figures. The notional assessments were vacated and $137,000 of the estimated balance came off, with a payment arrangement covering the rest.
Case Study 6 · Objection and relief
$68,000 Of Penalties And Interest Cancelled On Relief — Non-Resident Owning Canadian Rental, Guelph
Client: A non-resident owning Canadian rental property · Where: Guelph, Ontario · Engagement: 9 weeks, fixed fee
Penalties and interest cancelled$68,000
Relief groundsAccepted
AssessmentAdjusted to filed position
The situation
An assessment of $68,000 landed at a non-resident owning Canadian rental property in Guelph, Ontario following a desk review. The auditor had not seen the records behind US tax paid but no foreign tax credit claimed on the Canadian return.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, then set out the legislative basis for the position alongside the documents supporting it.
The result
$68,000 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.
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.
