International Tax Services Case Studies

6 International Tax Services 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 international tax services work, not a general example.

Case Study 1 · Backlog brought current

7 Years Filed, $71,000 Removed From The Assessed Balance — Non-Resident Owning Canadian Rental, Burnaby

Client: A non-resident owning Canadian rental property  ·  Where: Burnaby, British Columbia  ·  Engagement: 4 weeks, fixed fee

Years filed7
Assessed balance removed$71,000
CollectionsStopped

The situation

A non-resident owning Canadian rental property in Burnaby, British Columbia had not filed for 7 years. The CRA had issued arbitrary assessments, and the business was carrying foreign accounts that had passed the $100,000 T1135 threshold three years earlier 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 filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, 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 $71,000 of the estimated balance came off, with a payment arrangement covering the rest.

Case Study 2 · Objection and relief

$16,500 Of Penalties And Interest Cancelled On Relief — Dual Citizen with a, Kitchener

Client: A dual citizen with a US retirement account  ·  Where: Kitchener, Ontario  ·  Engagement: 6 weeks, fixed fee

Penalties and interest cancelled$16,500
Relief groundsAccepted
AssessmentAdjusted to filed position

The situation

An assessment of $16,500 landed at a dual citizen with a US retirement account in Kitchener, Ontario following a desk review. The auditor had not seen the records behind a departure year filed as a normal resident return with no deemed disposition reported.

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 set out the legislative basis for the position alongside the documents supporting it.

The result

$16,500 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.

Case Study 3 · Scaling without breaking

Second-Province Expansion Handled, $128,000 Of Cash Released — Emigrant Who Left Canada, Windsor

Client: An emigrant who left Canada mid-year  ·  Where: Windsor, Ontario  ·  Engagement: 5 weeks, fixed fee

Cash released$128,000
New registrationsComplete on day one
Compliance gapsNone

The situation

Revenue at an emigrant who left Canada mid-year in Windsor, Ontario was up sharply and cash was tighter than ever. Underneath it sat a US LLC taxed as a corporation in Canada, producing double tax on the same income.

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

$128,000 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 4 · Missed incentive claimed

$33,500 Credit Claim Filed And Accepted Without Adjustment — Canadian with a US, Kelowna

Client: A Canadian with a US employer  ·  Where: Kelowna, British Columbia  ·  Engagement: 3 weeks, fixed fee

Claim value$33,500
AcceptedWithout adjustment
RepeatableAnnually

The situation

A Canadian with a US employer in Kelowna, British Columbia assumed the credits did not apply to a business its size. A departure year filed as a normal resident return with no deemed disposition reported 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

$33,500 recovered. Because the eligibility analysis is on file, the same claim can be repeated each year with a fraction of the effort.

Case Study 5 · Deadline rescue

Filed On Time From A Standing Start, $140,000 Penalty Avoided — Inbound Transferee on Assignment, Toronto

Client: An inbound transferee on assignment  ·  Where: Toronto, Ontario  ·  Engagement: 7 weeks, fixed fee

Penalty avoided$140,000
Turnaround7 weeks
FiledOn time

The situation

An inbound transferee on assignment in Toronto, Ontario came to us 7 weeks before its filing deadline with 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. A late filing would have triggered a penalty of roughly $140,000 before interest.

What we did

We worked backwards from the deadline. We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, 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 $140,000 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.

Case Study 6 · Cash and remittance control

Remittance Schedule Corrected, $120,000 Refunded — Shareholder of a US, Mississauga

Client: A shareholder of a US LLC  ·  Where: Mississauga, Ontario  ·  Engagement: 3 weeks, fixed fee

Overpayment refunded$120,000
Late remittances sinceZero
ScheduleAutomated

The situation

Remittances at a shareholder of a US LLC in Mississauga, Ontario were consistently late by a few days, which was enough to trigger penalties every quarter. Behind it sat foreign accounts that had passed the $100,000 T1135 threshold three years earlier.

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 $120,000 of overpaid instalments was refunded.

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.

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