6 NR6 Undertaking to File a Section 216 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 nr6 undertaking to file a section 216 return work, not a general example.
Case Study 1 · CRA review defended
$41,000 Proposed Adjustment Withdrawn In Full — Shareholder of a US, London
Client: A shareholder of a US LLC · Where: London, Ontario · Engagement: 10 weeks, fixed fee
Adjustment withdrawn$41,000
File closed in10 weeks
Penalties assessedNone
The situation
A shareholder of a US LLC in London, Ontario received a proposal letter opening a review of nr6 undertaking to file a section 216 return. The CRA had identified foreign accounts that had passed the $100,000 T1135 threshold three years earlier and proposed an adjustment of $41,000, with 30 days to respond.
What we did
We treated the response as an evidence exercise rather than an argument. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, then indexed every supporting document against the specific line the auditor had questioned.
The result
The proposed adjustment was withdrawn in full — all $41,000 of it. The file closed in 10 weeks with no change to the assessed amounts and no penalty.
Case Study 2 · Cash and remittance control
$149,000 Of Working Capital Freed From The Tax Cycle — Inbound Transferee on Assignment, Calgary
Client: An inbound transferee on assignment · Where: Calgary, Alberta · Engagement: 6 weeks, fixed fee
Working capital freed$149,000
On-time remittancesEvery period since
Forecast horizon13 weeks
The situation
An inbound transferee on assignment in Calgary, Alberta was profitable on paper and short of cash every month. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net explained most of the gap.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely and built a thirteen-week cash view so tax payments stopped competing with payroll for the same dollars.
The result
$149,000 was released back into working capital. Remittances have been on time every period since, and the forecast shows the tax outflow before it lands.
Case Study 3 · Objection and relief
Notice Of Objection Allowed In Full, $65,000 Reversed — Canadian with a US, Kitchener
Client: A Canadian with a US employer · Where: Kitchener, Ontario · Engagement: 7 weeks, fixed fee
Amount reversed$65,000
ObjectionAllowed in full
Account balanceNil
The situation
A Canadian with a US employer in Kitchener, Ontario had been reassessed for $65,000 and had 11 days left on the objection deadline. The reassessment rested on US tax paid but no foreign tax credit claimed on the Canadian return.
What we did
We filed the objection inside the deadline with a complete submission rather than a placeholder, and reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.
The result
The appeals officer allowed the objection in full. $65,000 was reversed and the account returned to a nil balance.
Case Study 4 · Sale and succession
$790,000 Sheltered By The Lifetime Capital Gains Exemption — Emigrant Who Left Canada, Ottawa
Client: An emigrant who left Canada mid-year · Where: Ottawa, Ontario · Engagement: 10 weeks, fixed fee
Gain sheltered$790,000
ClosingOn schedule
Share qualificationMet
The situation
An emigrant who left Canada mid-year in Ottawa, Ontario had an offer on the table and 20 months to close. The shares did not qualify for the capital gains exemption, and a shareholder loan balance that would have been picked up as income on closing was part of the reason.
What we did
We purified the corporation so the shares met the qualifying tests, then filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund well ahead of the closing date.
The result
The sale closed on schedule with $790,000 sheltered by the lifetime capital gains exemption across the shareholders.
Case Study 5 · Cross-border exposure resolved
Foreign Reporting Brought Current, $15,000 Recovered — Dual Citizen with a, Moncton
Client: A dual citizen with a US retirement account · Where: Moncton, New Brunswick · Engagement: 5 weeks, fixed fee
Amount recovered$15,000
Reporting statusCurrent
Annual effortHours, not weeks
The situation
Foreign holdings at a dual citizen with a US retirement account in Moncton, New Brunswick had passed the reporting threshold without anyone noticing. Behind the disclosure problem sat a departure year filed as a normal resident return with no deemed disposition reported.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, claiming the treaty relief and foreign tax credits on the Canadian return and correcting the disclosure position for the open years.
The result
The treaty position was accepted and $15,000 was recovered. Reporting is now current and the annual process takes hours rather than weeks.
Case Study 6 · Scaling without breaking
Second-Province Expansion Handled, $140,000 Of Cash Released — Non-Resident Owning Canadian Rental, Halifax
Client: A non-resident owning Canadian rental property · Where: Halifax, Nova Scotia · Engagement: 5 weeks, fixed fee
Cash released$140,000
New registrationsComplete on day one
Compliance gapsNone
The situation
Revenue at a non-resident owning Canadian rental property in Halifax, Nova Scotia was up sharply and cash was tighter than ever. Underneath it sat foreign accounts that had passed the $100,000 T1135 threshold three years earlier.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. Every new obligation — registration, remittance frequency, provincial filing — was set up before it was triggered, not after.
The result
$140,000 of cash was released from the working capital cycle, and the expansion completed with every registration and filing obligation covered from day one.
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.
