NR73 Residency Determination Assistance Case Studies
6 worked NR73 Residency Determination Assistance 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 nr73 residency determination assistance work, not a specific client's file.
Case Study 1 · Sale and succession
Intergenerational Transfer Completed With $680,000 Deferred — Long-Stay Visitor, Barrie
Client: A long-stay visitor to Canada · Where: Barrie, Ontario · Engagement: 5 weeks, fixed fee
Tax deferred$680,000
TransferCompleted
RecordsReview-ready
The situation — A long-stay visitor to Canada, Barrie, Ontario
A generational transfer at a long-stay visitor to Canada in Barrie, Ontario had been discussed for years without a plan. No valuation on file to support the price the parties had agreed meant the transfer as contemplated would have been fully taxable.
What we did for A long-stay visitor to Canada, Barrie, Ontario
We put an NR6 undertaking in place with the Canadian agent so the following year was withheld on estimated net rent rather than on gross. We sequenced the steps so each one was complete and documented before the next depended on it.
The result — A long-stay visitor to Canada, Barrie, Ontario
$680,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
Case Study 2 · Objection and relief
Desk-Review Assessment Of $131,000 Vacated — Non-Resident Shareholder, Kelowna
Client: A non-resident shareholder drawing dividends · Where: Kelowna, British Columbia · Engagement: 4 weeks, fixed fee
Assessment vacated$131,000
Supporting recordsNow on file
AccountCleared
The situation — A non-resident shareholder drawing dividends, Kelowna, British Columbia
A non-resident shareholder drawing dividends in Kelowna, British Columbia was carrying $131,000 of penalties and interest. The charges arose from personal credits claimed in full for a year of part-year residency, as though the taxpayer had been resident from January. Much of that amount accumulated during a period the CRA itself had delayed.
What we did for A non-resident shareholder drawing dividends, Kelowna, British Columbia
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. We framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result — A non-resident shareholder drawing dividends, Kelowna, British Columbia
The assessment was vacated. $131,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 3 · Cash and remittance control
$61,000 Of Working Capital Freed From The Tax Cycle — Non-Resident Pensioner, Guelph
The situation — A non-resident pension recipient, Guelph, Ontario
A non-resident pension recipient in Guelph, Ontario was profitable on paper and short of cash every month. More than half the year spent in Canada on visits while the returns continued to be filed as a non-resident explained most of the gap.
What we did for A non-resident pension recipient, Guelph, Ontario
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 also built a thirteen-week cash view so tax payments stopped competing with payroll for the same dollars.
The result — A non-resident pension recipient, Guelph, Ontario
$61,000 was released back into working capital. Remittances have been on time every period since, and the forecast shows the tax outflow before it lands.
Client: A non-resident performer working in Canada · Where: Lethbridge, Alberta · Engagement: 10 weeks, fixed fee
Proposed tax cleared$92,000
Review duration10 weeks
OutcomeNo change
The situation — A non-resident performer working in Canada, Lethbridge, Alberta
A non-resident performer working in Canada in Lethbridge, Alberta was selected for review. Withholding taken on gross Canadian rent for three years with no section 216 return ever filed had shown up in the CRA's automated matching. The proposed adjustment on NR73 residency determination assistance came to $92,000.
What we did for A non-resident performer working in Canada, Lethbridge, Alberta
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. Every figure in the response traced to a source record the auditor could verify without asking a second question.
The result — A non-resident performer working in Canada, Lethbridge, Alberta
The review closed with no change. $92,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.
Case Study 5 · Backlog brought current
4 Years Filed, $66,000 Removed From The Assessed Balance — Dual-Resident Professional, Toronto
Client: A dual-resident professional · Where: Toronto, Ontario · Engagement: 7 weeks, fixed fee
Years filed4
Assessed balance removed$66,000
CollectionsStopped
The situation — A dual-resident professional, Toronto, Ontario
A dual-resident professional in Toronto, Ontario had not filed for 4 years. The CRA had issued arbitrary assessments. The business was carrying a non-resident disposition of Canadian property completed with no clearance certificate on file and a quarter of the price still held back. That came on top of a growing interest balance.
What we did for A dual-resident professional, Toronto, Ontario
We started with the oldest year and worked forward so each year's closing balances fed the next. We worked the treaty tie-breaker in order: permanent home, then centre of vital interests, then habitual abode. We put the supporting facts in the file rather than asserting the conclusion on the return. We filed the years in sequence rather than all at once.
The result — A dual-resident professional, Toronto, Ontario
Every year is now filed and assessed on actual figures. The notional assessments were vacated and $66,000 of the estimated balance came off, with a payment arrangement covering the rest.
Case Study 6 · Deadline rescue
Filed On Time From A Standing Start, $96,000 Penalty Avoided — Non-Resident Director, Calgary
Client: A non-resident director of a Canadian corporation · Where: Calgary, Alberta · Engagement: 11 weeks, fixed fee
Penalty avoided$96,000
Turnaround11 weeks
FiledOn time
The situation — A non-resident director of a Canadian corporation, Calgary, Alberta
A non-resident director of a Canadian corporation in Calgary, Alberta came to us 11 weeks before its filing deadline. The file came with an arrival year reported from January rather than from the date residency actually began. A late filing would have triggered a penalty of roughly $96,000 before interest.
What we did for A non-resident director of a Canadian corporation, Calgary, Alberta
We worked backwards from the deadline. We reported the deemed disposition on the return for the year residency ended. We elected to defer the tax against acceptable security, so nothing was payable until the property was actually sold. We prioritised the items that actually gated the filing and deferred everything that did not.
The result — A non-resident director of a Canadian corporation, Calgary, Alberta
The return was filed on time and complete. The $96,000 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.
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.
