6 worked International Tax Structuring 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 structuring work, not a specific client's file.
Case Study 1 · CRA review defended
Audit Defence Closed In 3 Weeks, $28,500 Cleared — US Retirement Account Holder, Lethbridge
Client: A dual citizen with a US retirement account · Where: Lethbridge, Alberta · Engagement: 3 weeks, fixed fee
Proposed tax cleared$28,500
Review duration3 weeks
OutcomeNo change
The situation — A dual citizen with a US retirement account, Lethbridge, Alberta
A dual citizen with a US retirement account in Lethbridge, Alberta was selected for review. Invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken had shown up in the CRA's automated matching. The proposed adjustment on international tax structuring came to $28,500.
What we did for A dual citizen with a US retirement account, Lethbridge, Alberta
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. Every figure in the response traced to a source record the auditor could verify without asking a second question.
The result — A dual citizen with a US retirement account, Lethbridge, Alberta
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 on US Payroll, Barrie
Client: A Canadian with a US employer · Where: Barrie, Ontario · Engagement: 6 weeks, fixed fee
Annual saving$17,000
ReorganisationTax-neutral
StructureMatches operations
The situation — A Canadian with a US employer, Barrie, Ontario
The structure at a Canadian with a US employer in Barrie, Ontario needed fixing. The file was carrying a US LLC taxed as a corporation in Canada, producing double tax on the same income. Every option for fixing it ran through a reorganisation that had to be done without triggering tax.
What we did for A Canadian with a US employer, Barrie, Ontario
We worked with the client's lawyer. Together, we reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. We also prepared the elections, resolutions and valuations the structure needed to stand up.
The result — A Canadian with a US employer, Barrie, Ontario
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 — US LLC Shareholder, Victoria
Client: A shareholder of a US LLC · Where: Victoria, British Columbia · Engagement: 3 weeks, fixed fee
Assessment vacated$53,000
Supporting recordsNow on file
AccountCleared
The situation — A shareholder of a US LLC, Victoria, British Columbia
A shareholder of a US LLC in Victoria, British Columbia was carrying $53,000 of penalties and interest. The charges arose from dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability. Much of that amount accumulated during a period the CRA itself had delayed.
What we did for A shareholder of a US LLC, Victoria, British Columbia
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A shareholder of a US LLC, Victoria, British Columbia
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 — Cross-Border Contractor, Regina
Client: A contractor working on both sides of the border · Where: Regina, Saskatchewan · Engagement: 3 weeks, fixed fee
Combined saving$18,000
ScopeCorporate + personal
Future yearsNo rework needed
The situation — A contractor working on both sides of the border, Regina, Saskatchewan
Nothing was wrong at a contractor working on both sides of the border in Regina, Saskatchewan. 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.
What we did for A contractor working on both sides of the border, Regina, Saskatchewan
We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. We 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 — A contractor working on both sides of the border, Regina, Saskatchewan
$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 Pension Recipient, London
Client: A Canadian resident receiving US pension income · Where: London, Ontario · Engagement: 4 weeks, fixed fee
Withholding refunded$15,000
ElectionFiled and accepted
Cross-border reportingConsistent
The situation — A Canadian resident receiving US pension income, London, Ontario
A Canadian resident receiving US pension income in London, Ontario was paying tax in two countries on one stream of income. Winters spent in the United States with the day count kept casually and no residency position documented anywhere had never been reviewed against the treaty.
What we did for A Canadian resident receiving US pension income, London, Ontario
We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. We also coordinated the timing so the credit claimed in Canada matched the tax actually paid abroad.
The result — A Canadian resident receiving US pension income, London, Ontario
$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 — US Citizen in Canada, Surrey
Client: A US citizen living in Canada · Where: Surrey, British Columbia · Engagement: 11 weeks, fixed fee
Years filed6
Assessed balance removed$118,000
CollectionsStopped
The situation — A US citizen living in Canada, Surrey, British Columbia
A US citizen living in Canada in Surrey, British Columbia had not filed for 6 years. The CRA had issued arbitrary assessments. The business was carrying a departure year filed as a normal resident return with no deemed disposition reported. That came on top of a growing interest balance.
What we did for A US citizen living in Canada, Surrey, British Columbia
We started with the oldest year and worked forward so each year's closing balances fed the next. 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. We filed the years in sequence rather than all at once.
The result — A US citizen living in Canada, Surrey, British Columbia
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 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.
