6 worked International Tax Services 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 international tax services work, not a specific client's file.
Case Study 1 · Backlog brought current
7 Years Filed, $71,000 Removed From The Assessed Balance — Mid-Year Emigrant, Burnaby
Client: An emigrant who left Canada mid-year · Where: Burnaby, British Columbia · Engagement: 4 weeks, fixed fee
Years filed7
Assessed balance removed$71,000
CollectionsStopped
The situation — An emigrant who left Canada mid-year, Burnaby, British Columbia
An emigrant who left Canada mid-year in Burnaby, British Columbia had not filed for 7 years. The CRA had issued arbitrary assessments. The business was carrying 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. That came on top of a growing interest balance.
What we did for An emigrant who left Canada mid-year, Burnaby, British Columbia
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. We filed the years in sequence rather than all at once.
The result — An emigrant who left Canada mid-year, Burnaby, British Columbia
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 — US LLC Shareholder, Kitchener
Client: A shareholder of a US LLC · Where: Kitchener, Ontario · Engagement: 6 weeks, fixed fee
Penalties and interest cancelled$16,500
Relief groundsAccepted
AssessmentAdjusted to filed position
The situation — A shareholder of a US LLC, Kitchener, Ontario
An assessment of $16,500 landed at a shareholder of a US LLC in Kitchener, Ontario following a desk review. It turned on winters spent in the United States with the day count kept casually and no residency position documented anywhere. The auditor had not seen the records behind it.
What we did for A shareholder of a US LLC, Kitchener, Ontario
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We then set out the legislative basis for the position alongside the documents supporting it.
The result — A shareholder of a US LLC, Kitchener, Ontario
$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 — Florida Property Owner, Windsor
Client: A family with a Florida vacation property · Where: Windsor, Ontario · Engagement: 5 weeks, fixed fee
Cash released$128,000
New registrationsComplete on day one
Compliance gapsNone
The situation — A family with a Florida vacation property, Windsor, Ontario
Revenue at a family with a Florida vacation property in Windsor, Ontario was up sharply and cash was tighter than ever. Underneath it sat US tax paid but no foreign tax credit claimed on the Canadian return.
What we did for A family with a Florida vacation property, Windsor, Ontario
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. Every new obligation was set up before it was triggered, not after. That covered registration, remittance frequency and provincial filing.
The result — A family with a Florida vacation property, Windsor, Ontario
$128,000 of cash was released from the working capital cycle. 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 — US Citizen in Canada, Kelowna
Client: A US citizen living in Canada · Where: Kelowna, British Columbia · Engagement: 3 weeks, fixed fee
Claim value$33,500
AcceptedWithout adjustment
RepeatableAnnually
The situation — A US citizen living in Canada, Kelowna, British Columbia
A US citizen living in Canada in Kelowna, British Columbia assumed the credits did not apply to a business its size. US tax paid but no foreign tax credit claimed on the Canadian return meant they had applied all along.
What we did for A US citizen living in Canada, Kelowna, British Columbia
We identified the qualifying activity and built the documentation to support it. Then we aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns.
The result — A US citizen living in Canada, Kelowna, British Columbia
$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 — Non-Resident Landlord, Toronto
Client: A non-resident owning Canadian rental property · Where: Toronto, Ontario · Engagement: 7 weeks, fixed fee
Penalty avoided$140,000
Turnaround7 weeks
FiledOn time
The situation — A non-resident owning Canadian rental property, Toronto, Ontario
A non-resident owning Canadian rental property in Toronto, Ontario came to us 7 weeks before its filing deadline. The file came with dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability. A late filing would have triggered a penalty of roughly $140,000 before interest.
What we did for A non-resident owning Canadian rental property, Toronto, Ontario
We worked backwards from the deadline. We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. We prioritised the items that actually gated the filing and deferred everything that did not.
The result — A non-resident owning Canadian rental property, Toronto, Ontario
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 — Canadian on US Payroll, Mississauga
Client: A Canadian with a US employer · Where: Mississauga, Ontario · Engagement: 3 weeks, fixed fee
Overpayment refunded$120,000
Late remittances sinceZero
ScheduleAutomated
The situation — A Canadian with a US employer, Mississauga, Ontario
Remittances at a Canadian with a US employer in Mississauga, Ontario were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat a departure year filed as a normal resident return with no deemed disposition reported.
What we did for A Canadian with a US employer, Mississauga, Ontario
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. Then we moved the remittance dates into a scheduled process rather than a monthly decision.
The result — A Canadian with a US employer, Mississauga, Ontario
Penalties stopped from the following remittance onwards, and $120,000 of overpaid instalments was refunded.
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.
