6 worked Non-Resident Corporation Tax Return 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 non-resident corporation tax return work, not a specific client's file.
Case Study 1 · Backlog brought current
$95,000 Of Arbitrary Assessments Vacated After 7 Years — US-Facing Canadian Corporation, Burnaby
Client: A Canadian corporation with US customers · Where: Burnaby, British Columbia · Engagement: 6 weeks, fixed fee
Arbitrary tax vacated$95,000
Years brought current7
Account statusCurrent
The situation — A Canadian corporation with US customers, Burnaby, British Columbia
7 years of unfiled returns had turned into notional assessments at a Canadian corporation with US customers in Burnaby, British Columbia. Underneath lay 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. Collections had already started.
What we did for A Canadian corporation with US customers, Burnaby, British Columbia
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. We then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.
The result — A Canadian corporation with US customers, Burnaby, British Columbia
All 7 years were accepted as filed. $95,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 7 years.
Case Study 2 · Deadline rescue
$77,000 Late-Filing Penalty Cancelled On Relief Application — US Branch Operator, Regina
Client: A Canadian corporation operating a US branch · Where: Regina, Saskatchewan · Engagement: 7 weeks, fixed fee
Penalty cancelled$77,000
Relief applicationGranted
ReturnAccepted as filed
The situation — A Canadian corporation operating a US branch, Regina, Saskatchewan
A Canadian corporation operating a US branch in Regina, Saskatchewan had already missed one deadline and was about to miss a second. Behind it sat a departure year filed as a normal resident return with no deemed disposition reported. A penalty of $77,000 was accruing.
What we did for A Canadian corporation operating a US branch, Regina, Saskatchewan
We split the work into what had to happen before the deadline and what could follow it. Then 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.
The result — A Canadian corporation operating a US branch, Regina, Saskatchewan
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $77,000 of the penalty already assessed on the earlier year.
Case Study 3 · Planning that cut the bill
Remuneration Review Saved $32,000 Across Corporate And Personal Returns — Non-Resident Landlord, Red Deer
Client: A non-resident owning Canadian rental property · Where: Red Deer, Alberta · Engagement: 6 weeks, fixed fee
Combined saving$32,000
ScopeCorporate + personal
Future yearsNo rework needed
The situation — A non-resident owning Canadian rental property, Red Deer, Alberta
Nothing was wrong at a non-resident owning Canadian rental property in Red Deer, Alberta. The filings were on time and accurate. What they were not was planned. US tax paid but no foreign tax credit claimed on the Canadian return had never been reviewed.
What we did for A non-resident owning Canadian rental property, Red Deer, Alberta
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. 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 non-resident owning Canadian rental property, Red Deer, Alberta
$32,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
Case Study 4 · Missed incentive claimed
$95,000 In Credits Claimed That Prior Filings Had Missed — Florida Property Owner, Windsor
Client: A family with a Florida vacation property · Where: Windsor, Ontario · Engagement: 7 weeks, fixed fee
Credits claimed$95,000
Years adjusted6
Review outcomeNo adjustment
The situation — A family with a Florida vacation property, Windsor, Ontario
A family with a Florida vacation property in Windsor, Ontario had been filing for 6 years. In that time, the incentives its activity qualified for were never claimed. Behind that sat invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken.
What we did for A family with a Florida vacation property, Windsor, Ontario
We tested each activity against the eligibility criteria rather than the description on the invoice. Then we reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.
The result — A family with a Florida vacation property, Windsor, Ontario
$95,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Client: An emigrant who left Canada mid-year · Where: Barrie, Ontario · Engagement: 6 weeks, fixed fee
Annual saving$32,000
ReorganisationTax-neutral
StructureMatches operations
The situation — An emigrant who left Canada mid-year, Barrie, Ontario
The structure at an emigrant who left Canada mid-year in Barrie, Ontario needed fixing. The file was carrying dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability. Every option for fixing it ran through a reorganisation that had to be done without triggering tax.
What we did for An emigrant who left Canada mid-year, Barrie, Ontario
We worked with the client's lawyer. Together, 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 prepared the elections, resolutions and valuations the structure needed to stand up.
The result — An emigrant who left Canada mid-year, Barrie, Ontario
The structure now matches the business. Annual saving of $32,000, and the reorganisation itself was tax-neutral.
Case Study 6 · Records and systems rebuilt
Books Rebuilt From Source, $18,000 In Unclaimed Input Tax Found — US Rental Owner, Guelph
Client: A Canadian resident with a US rental property · Where: Guelph, Ontario · Engagement: 3 weeks, fixed fee
Unclaimed tax found$18,000
Records rebuilt25 months
ProcessDocumented
The situation — A Canadian resident with a US rental property, Guelph, Ontario
A Canadian resident with a US rental property in Guelph, Ontario could not answer basic questions about its own numbers. Winters spent in the United States with the day count kept casually and no residency position documented anywhere sat between the bank statements and the ledger.
What we did for A Canadian resident with a US rental property, Guelph, Ontario
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We then documented the process so the work does not depend on any one person remembering how it was done.
The result — A Canadian resident with a US rental property, Guelph, Ontario
Records rebuilt and reconciled, $18,000 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.
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.
