6 NR4 Withholding Tax 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 nr4 withholding tax return work, not a general example.
Case Study 1 · Objection and relief
Desk-Review Assessment Of $82,000 Vacated — Canadian with a US, Halifax
Client: A Canadian with a US employer · Where: Halifax, Nova Scotia · Engagement: 4 weeks, fixed fee
Assessment vacated$82,000
Supporting recordsNow on file
AccountCleared
The situation
A Canadian with a US employer in Halifax, Nova Scotia was carrying $82,000 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 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. $82,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 2 · Scaling without breaking
Growth Handled Without A Missed Filing, $135,000 Freed — Non-Resident Owning Canadian Rental, Surrey
Client: A non-resident owning Canadian rental property · Where: Surrey, British Columbia · Engagement: 10 weeks, fixed fee
Cash freed$135,000
Compliance failuresNone
ReportingMonthly
The situation
A non-resident owning Canadian rental property in Surrey, British Columbia was opening in a second province — different filing obligations, a different payroll regime, and 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net already in the file.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely and put monthly reporting in place so the owner could see the cash effect of growth while there was still time to act on it.
The result
Growth was absorbed without a compliance failure. $135,000 of cash was released, and the monthly reporting now flags a problem while it is still small.
Case Study 3 · Missed incentive claimed
Incentive Review Recovered $18,500 Across 3 Open Years — US Citizen Living in, Hamilton
Client: A US citizen living in Canada · Where: Hamilton, Ontario · Engagement: 3 weeks, fixed fee
Recovered$18,500
Open years claimed3
Ongoing trackingIn place
The situation
An incentive review at a US citizen living in Canada in Hamilton, Ontario started from a simple question: what has never been claimed? The answer ran to 3 years, driven by foreign accounts that had passed the $100,000 T1135 threshold three years earlier.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, documenting eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result
The credits produced $18,500 across the open years, and the tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.
Case Study 4 · Backlog brought current
7 Years Filed, $13,500 Removed From The Assessed Balance — Inbound Transferee on Assignment, Winnipeg
Client: An inbound transferee on assignment · Where: Winnipeg, Manitoba · Engagement: 7 weeks, fixed fee
Years filed7
Assessed balance removed$13,500
CollectionsStopped
The situation
An inbound transferee on assignment in Winnipeg, Manitoba had not filed for 7 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 section 216 election with the supporting rental statements and recovered the excess withholding as a refund, 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 $13,500 of the estimated balance came off, with a payment arrangement covering the rest.
Case Study 5 · Cash and remittance control
Remittance Schedule Corrected, $27,000 Refunded — Dual Citizen with a, Ottawa
Client: A dual citizen with a US retirement account · Where: Ottawa, Ontario · Engagement: 6 weeks, fixed fee
Overpayment refunded$27,000
Late remittances sinceZero
ScheduleAutomated
The situation
Remittances at a dual citizen with a US retirement account in Ottawa, Ontario were consistently late by a few days, which was enough to trigger penalties every quarter. Behind it sat US tax paid but no foreign tax credit claimed on the Canadian return.
What we did
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused, then moved the remittance dates into a scheduled process rather than a monthly decision.
The result
Penalties stopped from the following remittance onwards, and $27,000 of overpaid instalments was refunded.
Case Study 6 · Cross-border exposure resolved
$83,000 Of Excess Withholding Refunded On Election — Canadian Corporation with US, Edmonton
Client: A Canadian corporation with US customers · Where: Edmonton, Alberta · Engagement: 3 weeks, fixed fee
Withholding refunded$83,000
ElectionFiled and accepted
Cross-border reportingConsistent
The situation
A Canadian corporation with US customers in Edmonton, Alberta 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 filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely and coordinated the timing so the credit claimed in Canada matched the tax actually paid abroad.
The result
$83,000 of excess withholding was refunded and the exposure closed. Both sides of the border now report consistently, which is what keeps the credit claimable.
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.
