6 worked Non-Resident 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 non-resident tax services work, not a specific client's file.
Case Study 1 · Planning that cut the bill
$38,000 Cut From The Annual Tax Bill — Non-Resident Performer, Vancouver
Client: A non-resident performer working in Canada · Where: Vancouver, British Columbia · Engagement: 7 weeks, fixed fee
First-year saving$38,000
RepeatsAnnually
Filing positionUnchanged in risk
The situation — A non-resident performer working in Canada, Vancouver, British Columbia
A non-resident performer working in Canada in Vancouver, British Columbia was compliant but paying more than it needed to. The prior year had been filed correctly. It still left a house in Canada still available for occupation and a spouse still resident, while the returns were filed as a non-resident on the table.
What we did for A non-resident performer working in Canada, Vancouver, British Columbia
We modelled the current position against the alternatives before changing anything. Then we filed the section 217 election after running the calculation both ways. The Canadian pension and benefit income was then taxed under the ordinary rate structure rather than at the flat withholding rate.
The result — A non-resident performer working in Canada, Vancouver, British Columbia
The change saved $38,000 in the first year and repeats annually. Nothing about the filings became more aggressive. The position is simply the one the rules already allowed.
Case Study 2 · CRA review defended
$108,000 Proposed Adjustment Withdrawn In Full — Non-Resident Pensioner, Victoria
Client: A non-resident pension recipient · Where: Victoria, British Columbia · Engagement: 5 weeks, fixed fee
Adjustment withdrawn$108,000
File closed in5 weeks
Penalties assessedNone
The situation — A non-resident pension recipient, Victoria, British Columbia
A non-resident pension recipient in Victoria, British Columbia received a proposal letter opening a review of non-resident tax services. The CRA had identified a non-resident disposition of Canadian property completed with no clearance certificate on file and a quarter of the price still held back. It proposed an adjustment of $108,000, with 30 days to respond.
What we did for A non-resident pension recipient, Victoria, British Columbia
We treated the response as an evidence exercise rather than an argument. We documented the fair market value of each property as at the date residency began. That way the deemed acquisition cost was on file long before a sale put it in issue. We then indexed every supporting document against the specific line the auditor had questioned.
The result — A non-resident pension recipient, Victoria, British Columbia
The proposed adjustment was withdrawn in full — all $108,000 of it. The file closed in 5 weeks with no change to the assessed amounts and no penalty.
Case Study 3 · Sale and succession
Intergenerational Transfer Completed With $225,000 Deferred — Non-Resident Director, Surrey
Client: A non-resident director of a Canadian corporation · Where: Surrey, British Columbia · Engagement: 3 weeks, fixed fee
Tax deferred$225,000
TransferCompleted
RecordsReview-ready
The situation — A non-resident director of a Canadian corporation, Surrey, British Columbia
A generational transfer at a non-resident director of a Canadian corporation in Surrey, British Columbia had been discussed for years without a plan. Passive assets sitting inside the operating company, disqualifying the shares meant the transfer as contemplated would have been fully taxable.
What we did for A non-resident director of a Canadian corporation, Surrey, British Columbia
We counted the days of presence in Canada year by year and established that the deemed residence rule had been triggered. We brought the world-income returns current for the affected years. We sequenced the steps so each one was complete and documented before the next depended on it.
The result — A non-resident director of a Canadian corporation, Surrey, British Columbia
$225,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
Case Study 4 · Records and systems rebuilt
Books Rebuilt From Source, $13,000 In Unclaimed Input Tax Found — Dual-Resident Professional, Lethbridge
Client: A dual-resident professional · Where: Lethbridge, Alberta · Engagement: 6 weeks, fixed fee
Unclaimed tax found$13,000
Records rebuilt25 months
ProcessDocumented
The situation — A dual-resident professional, Lethbridge, Alberta
A dual-resident professional in Lethbridge, Alberta could not answer basic questions about its own numbers. Rent remitted abroad in full by a Canadian agent who had never been told the withholding was their obligation sat between the bank statements and the ledger.
What we did for A dual-resident professional, Lethbridge, Alberta
We split the year at the residency date and prorated the personal credits to the days of residency. We refiled the years that had claimed the full amounts. We then documented the process so the work does not depend on any one person remembering how it was done.
The result — A dual-resident professional, Lethbridge, Alberta
Records rebuilt and reconciled, $13,000 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.
Case Study 5 · Missed incentive claimed
$33,500 In Credits Claimed That Prior Filings Had Missed — First-Year Resident, Regina
Client: A first-year Canadian resident · Where: Regina, Saskatchewan · Engagement: 4 weeks, fixed fee
Credits claimed$33,500
Years adjusted5
Review outcomeNo adjustment
The situation — A first-year Canadian resident, Regina, Saskatchewan
A first-year Canadian resident in Regina, Saskatchewan had been filing for 5 years. In that time, the incentives its activity qualified for were never claimed. Behind that sat rent remitted abroad in full by a Canadian agent who had never been told the withholding was their obligation.
What we did for A first-year Canadian resident, Regina, Saskatchewan
We tested each activity against the eligibility criteria rather than the description on the invoice. Then we mapped the residential ties on each side of the departure date and fixed the date residency actually ceased. We filed the emigrant return with the deemed disposition and the property list built on that date.
The result — A first-year Canadian resident, Regina, Saskatchewan
$33,500 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 6 · Backlog brought current
$141,000 Of Arbitrary Assessments Vacated After 7 Years — Non-Resident Vendor, Ottawa
The situation — A non-resident property vendor, Ottawa, Ontario
7 years of unfiled returns had turned into notional assessments at a non-resident property vendor in Ottawa, Ontario. Underneath lay a newcomer year with nothing in the file to show what the foreign property was worth on the date of arrival. Collections had already started.
What we did for A non-resident property vendor, Ottawa, Ontario
We filed the notification of disposition and obtained the clearance certificate. We released the proceeds the purchaser had been holding against a withholding calculated on the gross price. We then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.
The result — A non-resident property vendor, Ottawa, Ontario
All 7 years were accepted as filed. $141,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 7 years.
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.
