6 Regulation 105 Withholding and 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 105 withholding and waiver work, not a general example.
Case Study 1 · Scaling without breaking
Second-Province Expansion Handled, $100,000 Of Cash Released — Non-Resident Owning Canadian Rental, Windsor
Client: A non-resident owning Canadian rental property · Where: Windsor, Ontario · Engagement: 11 weeks, fixed fee
Cash released$100,000
New registrationsComplete on day one
Compliance gapsNone
The situation
Revenue at a non-resident owning Canadian rental property in Windsor, Ontario 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
$100,000 of cash was released from the working capital cycle, and the expansion completed with every registration and filing obligation covered from day one.
Case Study 2 · Structure rebuilt
Corporate Structure Rebuilt For $72,000 Of Annual Savings — Inbound Transferee on Assignment, Red Deer
Client: An inbound transferee on assignment · Where: Red Deer, Alberta · Engagement: 9 weeks, fixed fee
Saving per year$72,000
DocumentationComplete
Transfer basisRollover
The situation
The structure at an inbound transferee on assignment in Red Deer, Alberta had been set up years earlier for a business that no longer existed, and a US LLC taxed as a corporation in Canada, producing double tax on the same income had become expensive.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result
$72,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 3 · Planning that cut the bill
$25,000 Saved By Correcting What Prior Filings Had Missed — Canadian Corporation with US, Regina
Client: A Canadian corporation with US customers · Where: Regina, Saskatchewan · Engagement: 3 weeks, fixed fee
Saving identified$25,000
RecurringYes
Positions documentedAll
The situation
A Canadian corporation with US customers in Regina, Saskatchewan asked for a second opinion on regulation 105 withholding and waiver after three years of rising tax. The review found 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
What we did
We built the comparison first — current structure against two alternatives — and then filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund.
The result
First-year saving of $25,000, with the same benefit recurring. Every position taken is documented and supported in the file.
Case Study 4 · Backlog brought current
$43,000 Of Arbitrary Assessments Vacated After 5 Years — Emigrant Who Left Canada, Burnaby
Client: An emigrant who left Canada mid-year · Where: Burnaby, British Columbia · Engagement: 9 weeks, fixed fee
Arbitrary tax vacated$43,000
Years brought current5
Account statusCurrent
The situation
5 years of unfiled returns had turned into notional assessments at an emigrant who left Canada mid-year in Burnaby, British Columbia, with a departure year filed as a normal resident return with no deemed disposition reported underneath. Collections had already started.
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 filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.
The result
All 5 years were accepted as filed. $43,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 5 years.
Case Study 5 · Cash and remittance control
Remittance Schedule Corrected, $37,000 Refunded — Canadian Resident with a, Saskatoon
Client: A Canadian resident with a US rental property · Where: Saskatoon, Saskatchewan · Engagement: 8 weeks, fixed fee
Overpayment refunded$37,000
Late remittances sinceZero
ScheduleAutomated
The situation
Remittances at a Canadian resident with a US rental property in Saskatoon, Saskatchewan 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 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 $37,000 of overpaid instalments was refunded.
Case Study 6 · Sale and succession
$385,000 Sheltered By The Lifetime Capital Gains Exemption — Dual Citizen with a, Surrey
Client: A dual citizen with a US retirement account · Where: Surrey, British Columbia · Engagement: 10 weeks, fixed fee
Gain sheltered$385,000
ClosingOn schedule
Share qualificationMet
The situation
A dual citizen with a US retirement account in Surrey, British Columbia had an offer on the table and 17 months to close. The shares did not qualify for the capital gains exemption, and a single shareholder holding every share, with no room to multiply the exemption was part of the reason.
What we did
We purified the corporation so the shares met the qualifying tests, then restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward well ahead of the closing date.
The result
The sale closed on schedule with $385,000 sheltered by the lifetime capital gains exemption across the shareholders.
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.
