6 worked Repatriation and Dividend Planning 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 repatriation and dividend planning work, not a specific client's file.
Client: A non-resident owning Canadian rental property · Where: Edmonton, Alberta · Engagement: 6 weeks, fixed fee
Annual saving$44,000
ReorganisationTax-neutral
StructureMatches operations
The situation — A non-resident owning Canadian rental property, Edmonton, Alberta
The structure at a non-resident owning Canadian rental property in Edmonton, Alberta needed fixing. The file was carrying 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. Every option for fixing it ran through a reorganisation that had to be done without triggering tax.
What we did for A non-resident owning Canadian rental property, Edmonton, Alberta
We worked with the client's lawyer. Together, we filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. We also prepared the elections, resolutions and valuations the structure needed to stand up.
The result — A non-resident owning Canadian rental property, Edmonton, Alberta
The structure now matches the business. Annual saving of $44,000, and the reorganisation itself was tax-neutral.
Case Study 2 · Deadline rescue
Filed On Time From A Standing Start, $38,500 Penalty Avoided — US Rental Owner, Winnipeg
Client: A Canadian resident with a US rental property · Where: Winnipeg, Manitoba · Engagement: 7 weeks, fixed fee
Penalty avoided$38,500
Turnaround7 weeks
FiledOn time
The situation — A Canadian resident with a US rental property, Winnipeg, Manitoba
A Canadian resident with a US rental property in Winnipeg, Manitoba came to us 7 weeks before its filing deadline. The file came with invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken. A late filing would have triggered a penalty of roughly $38,500 before interest.
What we did for A Canadian resident with a US rental property, Winnipeg, Manitoba
We worked backwards from the deadline. We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. We prioritised the items that actually gated the filing and deferred everything that did not.
The result — A Canadian resident with a US rental property, Winnipeg, Manitoba
The return was filed on time and complete. The $38,500 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.
Case Study 3 · Cash and remittance control
Remittance Schedule Corrected, $111,000 Refunded — US Branch Operator, Surrey
Client: A Canadian corporation operating a US branch · Where: Surrey, British Columbia · Engagement: 3 weeks, fixed fee
Overpayment refunded$111,000
Late remittances sinceZero
ScheduleAutomated
The situation — A Canadian corporation operating a US branch, Surrey, British Columbia
Remittances at a Canadian corporation operating a US branch in Surrey, British Columbia were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat foreign accounts that had passed the $100,000 T1135 threshold three years earlier.
What we did for A Canadian corporation operating a US branch, Surrey, British Columbia
We registered the payer for a non-resident withholding account, remitted the Regulation 105 amounts due, and applied for waivers covering the rest of the contract. Then we moved the remittance dates into a scheduled process rather than a monthly decision.
The result — A Canadian corporation operating a US branch, Surrey, British Columbia
Penalties stopped from the following remittance onwards, and $111,000 of overpaid instalments was refunded.
Case Study 4 · Cross-border exposure resolved
$41,000 Of Excess Withholding Refunded On Election — Mid-Year Emigrant, Saskatoon
Client: An emigrant who left Canada mid-year · Where: Saskatoon, Saskatchewan · Engagement: 4 weeks, fixed fee
Withholding refunded$41,000
ElectionFiled and accepted
Cross-border reportingConsistent
The situation — An emigrant who left Canada mid-year, Saskatoon, Saskatchewan
An emigrant who left Canada mid-year in Saskatoon, Saskatchewan was paying tax in two countries on one stream of income. A departure year filed as a normal resident return with no deemed disposition reported had never been reviewed against the treaty.
What we did for An emigrant who left Canada mid-year, Saskatoon, Saskatchewan
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We also coordinated the timing so the credit claimed in Canada matched the tax actually paid abroad.
The result — An emigrant who left Canada mid-year, Saskatoon, Saskatchewan
$41,000 of excess withholding was refunded and the exposure closed. Both sides of the border now report consistently, which is what keeps the credit claimable.
Case Study 5 · Records and systems rebuilt
18 Months Reconciled And $4,700 Of Input Tax Recovered — US-Facing Canadian Corporation, Burnaby
Client: A Canadian corporation with US customers · Where: Burnaby, British Columbia · Engagement: 11 weeks, fixed fee
Months reconciled18
Input tax recovered$4,700
Close time10 days
The situation — A Canadian corporation with US customers, Burnaby, British Columbia
Nothing reconciled at a Canadian corporation with US customers in Burnaby, British Columbia. Every filing started with 18 months of cleanup. The file was carrying dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability.
What we did for A Canadian corporation with US customers, Burnaby, British Columbia
We rebuilt from source rather than correcting on top of the existing file. We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. Then we set the routine that keeps it clean.
The result — A Canadian corporation with US customers, Burnaby, British Columbia
18 months reconciled to the bank. The close now takes 10 days, and $4,700 of previously unclaimable input tax was recovered in the process.
Case Study 6 · Planning that cut the bill
Remuneration Review Saved $28,500 Across Corporate And Personal Returns — Florida Property Owner, Regina
Client: A family with a Florida vacation property · Where: Regina, Saskatchewan · Engagement: 9 weeks, fixed fee
Combined saving$28,500
ScopeCorporate + personal
Future yearsNo rework needed
The situation — A family with a Florida vacation property, Regina, Saskatchewan
Nothing was wrong at a family with a Florida vacation property in Regina, Saskatchewan. The filings were on time and accurate. What they were not was planned. A US LLC taxed as a corporation in Canada, producing double tax on the same income had never been reviewed.
What we did for A family with a Florida vacation property, Regina, Saskatchewan
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. We ran the numbers across both the corporate and personal returns, so the saving was real rather than deferred into someone else's hands.
The result — A family with a Florida vacation property, Regina, Saskatchewan
$28,500 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.
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.
