6 Non-Resident Corporation T2 Return 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 non-resident corporation t2 return work, not a general example.
Case Study 1 · Missed incentive claimed
$49,000 Credit Claim Filed And Accepted Without Adjustment — US Citizen Living in, Mississauga
Client: A US citizen living in Canada · Where: Mississauga, Ontario · Engagement: 10 weeks, fixed fee
Claim value$49,000
AcceptedWithout adjustment
RepeatableAnnually
The situation
A US citizen living in Canada in Mississauga, Ontario assumed the credits did not apply to a business its size. A US LLC taxed as a corporation in Canada, producing double tax on the same income 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
$49,000 recovered. Because the eligibility analysis is on file, the same claim can be repeated each year with a fraction of the effort.
Case Study 2 · Records and systems rebuilt
Books Rebuilt From Source, $19,500 In Unclaimed Input Tax Found — Inbound Transferee on Assignment, Saskatoon
Client: An inbound transferee on assignment · Where: Saskatoon, Saskatchewan · Engagement: 6 weeks, fixed fee
Unclaimed tax found$19,500
Records rebuilt34 months
ProcessDocumented
The situation
An inbound transferee on assignment in Saskatoon, Saskatchewan could not answer basic questions about its own numbers, because US tax paid but no foreign tax credit claimed on the Canadian return sat between the bank statements and the ledger.
What we did
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, then documented the process so the work does not depend on any one person remembering how it was done.
The result
Records rebuilt and reconciled, $19,500 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.
Case Study 3 · Cross-border exposure resolved
$53,000 Of Excess Withholding Refunded On Election — Dual Citizen with a, Victoria
Client: A dual citizen with a US retirement account · Where: Victoria, British Columbia · Engagement: 4 weeks, fixed fee
Withholding refunded$53,000
ElectionFiled and accepted
Cross-border reportingConsistent
The situation
A dual citizen with a US retirement account in Victoria, British Columbia was paying tax in two countries on one stream of income, because a US LLC taxed as a corporation in Canada, producing double tax on the same income had never been reviewed against the treaty.
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 coordinated the timing so the credit claimed in Canada matched the tax actually paid abroad.
The result
$53,000 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 4 · Objection and relief
Desk-Review Assessment Of $14,500 Vacated — Canadian Corporation with US, Toronto
Client: A Canadian corporation with US customers · Where: Toronto, Ontario · Engagement: 9 weeks, fixed fee
Assessment vacated$14,500
Supporting recordsNow on file
AccountCleared
The situation
A Canadian corporation with US customers in Toronto, Ontario was carrying $14,500 of penalties and interest arising from a departure year filed as a normal resident return with no deemed disposition reported, much of it accumulated during a period the CRA itself had delayed.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely and framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result
The assessment was vacated. $14,500 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 5 · CRA review defended
$82,000 Reassessment Reduced To Nil On Review — Shareholder of a US, Hamilton
Client: A shareholder of a US LLC · Where: Hamilton, Ontario · Engagement: 6 weeks, fixed fee
Reassessment reduced toNil
Tax protected$82,000
Prior filingsUndisturbed
The situation
A review notice arrived at a shareholder of a US LLC in Hamilton, Ontario covering non-resident corporation t2 return for two tax years. The auditor's working position was an adjustment of $82,000, driven by foreign accounts that had passed the $100,000 T1135 threshold three years earlier.
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 $82,000 and leaving the prior filings undisturbed.
Case Study 6 · Deadline rescue
$94,000 Late-Filing Penalty Cancelled On Relief Application — Emigrant Who Left Canada, Regina
Client: An emigrant who left Canada mid-year · Where: Regina, Saskatchewan · Engagement: 4 weeks, fixed fee
Penalty cancelled$94,000
Relief applicationGranted
ReturnAccepted as filed
The situation
An emigrant who left Canada mid-year in Regina, Saskatchewan had already missed one deadline and was about to miss a second. Behind it sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net, and a penalty of $94,000 was accruing.
What we did
We split the work into what had to happen before the deadline and what could follow it, then filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund.
The result
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $94,000 of the penalty already assessed on the earlier year.
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.
