6 International Tax Structuring 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 structuring work, not a general example.
Case Study 1 · CRA review defended
Audit Defence Closed In 3 Weeks, $28,500 Cleared — Shareholder of a US, Lethbridge
Client: A shareholder of a US LLC · Where: Lethbridge, Alberta · Engagement: 3 weeks, fixed fee
Proposed tax cleared$28,500
Review duration3 weeks
OutcomeNo change
The situation
A shareholder of a US LLC in Lethbridge, Alberta was selected for review after foreign accounts that had passed the $100,000 T1135 threshold three years earlier showed up in the CRA's automated matching. The proposed adjustment on international tax structuring came to $28,500.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. Every figure in the response traced to a source record the auditor could verify without asking a second question.
The result
The review closed with no change. $28,500 of proposed tax came off the table, and the documentation now in place makes the next review a short one.
Case Study 2 · Structure rebuilt
Holding Structure Added, $17,000 Saved Annually — Canadian Corporation with US, Barrie
Client: A Canadian corporation with US customers · Where: Barrie, Ontario · Engagement: 6 weeks, fixed fee
Annual saving$17,000
ReorganisationTax-neutral
StructureMatches operations
The situation
A Canadian corporation with US customers in Barrie, Ontario was carrying 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net, and every option for fixing it ran through a reorganisation that had to be done without triggering tax.
What we did
Working with the client's lawyer, we filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely and prepared the elections, resolutions and valuations the structure needed to stand up.
The result
The structure now matches the business. Annual saving of $17,000, and the reorganisation itself was tax-neutral.
Case Study 3 · Objection and relief
Desk-Review Assessment Of $53,000 Vacated — Dual Citizen with a, Victoria
Client: A dual citizen with a US retirement account · Where: Victoria, British Columbia · Engagement: 3 weeks, fixed fee
Assessment vacated$53,000
Supporting recordsNow on file
AccountCleared
The situation
A dual citizen with a US retirement account in Victoria, British Columbia was carrying $53,000 of penalties and interest arising from US tax paid but no foreign tax credit claimed on the Canadian return, much of it accumulated during a period the CRA itself had delayed.
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 framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result
The assessment was vacated. $53,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 4 · Planning that cut the bill
Remuneration Review Saved $18,000 Across Corporate And Personal Returns — Inbound Transferee on Assignment, Regina
Client: An inbound transferee on assignment · Where: Regina, Saskatchewan · Engagement: 3 weeks, fixed fee
Combined saving$18,000
ScopeCorporate + personal
Future yearsNo rework needed
The situation
Nothing was wrong at an inbound transferee on assignment in Regina, Saskatchewan — 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
$18,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
Case Study 5 · Cross-border exposure resolved
$15,000 Of Excess Withholding Refunded On Election — US Citizen Living in, London
Client: A US citizen living in Canada · Where: London, Ontario · Engagement: 4 weeks, fixed fee
Withholding refunded$15,000
ElectionFiled and accepted
Cross-border reportingConsistent
The situation
A US citizen living in Canada in London, Ontario was paying tax in two countries on one stream of income, because a departure year filed as a normal resident return with no deemed disposition reported had never been reviewed against the treaty.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward and coordinated the timing so the credit claimed in Canada matched the tax actually paid abroad.
The result
$15,000 of excess withholding was refunded and the exposure closed. Both sides of the border now report consistently, which is what keeps the credit claimable.
Case Study 6 · Backlog brought current
6 Years Filed, $118,000 Removed From The Assessed Balance — Non-Resident Owning Canadian Rental, Surrey
Client: A non-resident owning Canadian rental property · Where: Surrey, British Columbia · Engagement: 11 weeks, fixed fee
Years filed6
Assessed balance removed$118,000
CollectionsStopped
The situation
A non-resident owning Canadian rental property in Surrey, British Columbia had not filed for 6 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 outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, 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 $118,000 of the estimated balance came off, with a payment arrangement covering the rest.
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.
