6 Regulation 102 Payroll Withholding Waiver 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 regulation 102 payroll withholding waiver work, not a general example.
Case Study 1 · Objection and relief
Notice Of Objection Allowed In Full, $78,000 Reversed — Canadian with a US, Halifax
Client: A Canadian with a US employer · Where: Halifax, Nova Scotia · Engagement: 11 weeks, fixed fee
Amount reversed$78,000
ObjectionAllowed in full
Account balanceNil
The situation
A Canadian with a US employer in Halifax, Nova Scotia had been reassessed for $78,000 and had 10 days left on the objection deadline. The reassessment rested on a departure year filed as a normal resident return with no deemed disposition reported.
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. $78,000 was reversed and the account returned to a nil balance.
Case Study 2 · Cash and remittance control
Remittance Schedule Corrected, $155,000 Refunded — US Citizen Living in, Mississauga
Client: A US citizen living in Canada · Where: Mississauga, Ontario · Engagement: 6 weeks, fixed fee
Overpayment refunded$155,000
Late remittances sinceZero
ScheduleAutomated
The situation
Remittances at a US citizen living in Canada in Mississauga, Ontario were consistently late by a few days, which was enough to trigger penalties every quarter. Behind it sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, then moved the remittance dates into a scheduled process rather than a monthly decision.
The result
Penalties stopped from the following remittance onwards, and $155,000 of overpaid instalments was refunded.
Case Study 3 · CRA review defended
$73,000 Proposed Adjustment Withdrawn In Full — Dual Citizen with a, Kelowna
Client: A dual citizen with a US retirement account · Where: Kelowna, British Columbia · Engagement: 5 weeks, fixed fee
Adjustment withdrawn$73,000
File closed in5 weeks
Penalties assessedNone
The situation
A dual citizen with a US retirement account in Kelowna, British Columbia received a proposal letter opening a review of regulation 102 payroll withholding waiver. The CRA had identified a US LLC taxed as a corporation in Canada, producing double tax on the same income and proposed an adjustment of $73,000, 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 $73,000 of it. The file closed in 5 weeks with no change to the assessed amounts and no penalty.
Case Study 4 · Backlog brought current
Collections Halted And $143,000 Cut From A 5-Year Backlog — Shareholder of a US, Kitchener
Client: A shareholder of a US LLC · Where: Kitchener, Ontario · Engagement: 9 weeks, fixed fee
Balance reduced by$143,000
Backlog cleared5 years
CollectionsHalted
The situation
By the time a shareholder of a US LLC in Kitchener, Ontario called, 5 years were outstanding and the CRA had assessed on estimates. Underneath it sat foreign accounts that had passed the $100,000 T1135 threshold three years earlier.
What we did
We reconstructed the records year by year and filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. Each filing replaced an arbitrary assessment with a real one.
The result
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $143,000, and a relief application addressed part of the accumulated interest.
Case Study 5 · Deadline rescue
5-Week Turnaround Beat The Deadline And Saved $45,000 — Snowbird Spending Winters in, Saskatoon
Client: A snowbird spending winters in Arizona · Where: Saskatoon, Saskatchewan · Engagement: 5 weeks, fixed fee
Late-filing penalty avoided$45,000
Filed with9 days to spare
Next yearPapers ready
The situation
With the deadline for regulation 102 payroll withholding waiver weeks away, a snowbird spending winters in Arizona in Saskatoon, Saskatchewan was carrying US tax paid but no foreign tax credit claimed on the Canadian return. The exposure if the date slipped was around $45,000.
What we did
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. The filing went in complete rather than provisional, so there was no amended return to follow.
The result
Filed with 9 days to spare. $45,000 in late-filing penalties avoided, and the working papers are ready for the following year.
Case Study 6 · Planning that cut the bill
$19,000 Saved By Correcting What Prior Filings Had Missed — Inbound Transferee on Assignment, Edmonton
Client: An inbound transferee on assignment · Where: Edmonton, Alberta · Engagement: 9 weeks, fixed fee
Saving identified$19,000
RecurringYes
Positions documentedAll
The situation
An inbound transferee on assignment in Edmonton, Alberta asked for a second opinion on regulation 102 payroll withholding waiver after three years of rising tax. The review found a departure year filed as a normal resident return with no deemed disposition reported.
What we did
We built the comparison first — current structure against two alternatives — and then filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely.
The result
First-year saving of $19,000, with the same benefit recurring. Every position taken is documented and supported in the file.
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.
