6 RRSP and 401(k) Cross-Border 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 rrsp and 401(k) cross-border tax work, not a general example.
Case Study 1 · Cross-border exposure resolved
Foreign Reporting Brought Current, $14,500 Recovered — US Citizen Living in, Hamilton
Client: A US citizen living in Canada · Where: Hamilton, Ontario · Engagement: 9 weeks, fixed fee
Amount recovered$14,500
Reporting statusCurrent
Annual effortHours, not weeks
The situation
Foreign holdings at a US citizen living in Canada in Hamilton, Ontario had passed the reporting threshold without anyone noticing. Behind the disclosure problem sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
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 $14,500 was recovered. Reporting is now current and the annual process takes hours rather than weeks.
Case Study 2 · Records and systems rebuilt
Books Rebuilt From Source, $20,000 In Unclaimed Input Tax Found — Shareholder of a US, Barrie
Client: A shareholder of a US LLC · Where: Barrie, Ontario · Engagement: 9 weeks, fixed fee
Unclaimed tax found$20,000
Records rebuilt14 months
ProcessDocumented
The situation
A shareholder of a US LLC in Barrie, Ontario could not answer basic questions about its own numbers, because US tax paid but no foreign tax credit claimed on the Canadian return sat between the bank statements and the ledger.
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 documented the process so the work does not depend on any one person remembering how it was done.
The result
Records rebuilt and reconciled, $20,000 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.
Case Study 3 · Missed incentive claimed
Incentive Review Recovered $108,000 Across 3 Open Years — Canadian with a US, Halifax
Client: A Canadian with a US employer · Where: Halifax, Nova Scotia · Engagement: 3 weeks, fixed fee
Recovered$108,000
Open years claimed3
Ongoing trackingIn place
The situation
An incentive review at a Canadian with a US employer in Halifax, Nova Scotia started from a simple question: what has never been claimed? The answer ran to 3 years, driven by foreign accounts that had passed the $100,000 T1135 threshold three years earlier.
What we did
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, documenting eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result
The credits produced $108,000 across the open years, and the tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.
Case Study 4 · Deadline rescue
9-Week Turnaround Beat The Deadline And Saved $71,000 — Dual Citizen with a, Guelph
Client: A dual citizen with a US retirement account · Where: Guelph, Ontario · Engagement: 9 weeks, fixed fee
Late-filing penalty avoided$71,000
Filed with18 days to spare
Next yearPapers ready
The situation
With the deadline for rrsp and 401(k) cross-border tax weeks away, a dual citizen with a US retirement account in Guelph, Ontario was carrying a departure year filed as a normal resident return with no deemed disposition reported. The exposure if the date slipped was around $71,000.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. The filing went in complete rather than provisional, so there was no amended return to follow.
The result
Filed with 18 days to spare. $71,000 in late-filing penalties avoided, and the working papers are ready for the following year.
Case Study 5 · CRA review defended
$56,000 Proposed Adjustment Withdrawn In Full — Snowbird Spending Winters in, London
Client: A snowbird spending winters in Arizona · Where: London, Ontario · Engagement: 7 weeks, fixed fee
Adjustment withdrawn$56,000
File closed in7 weeks
Penalties assessedNone
The situation
A snowbird spending winters in Arizona in London, Ontario received a proposal letter opening a review of rrsp and 401(k) cross-border tax. The CRA had identified foreign accounts that had passed the $100,000 T1135 threshold three years earlier and proposed an adjustment of $56,000, 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 $56,000 of it. The file closed in 7 weeks with no change to the assessed amounts and no penalty.
Case Study 6 · Objection and relief
Desk-Review Assessment Of $51,000 Vacated — Canadian Corporation with US, Toronto
Client: A Canadian corporation with US customers · Where: Toronto, Ontario · Engagement: 7 weeks, fixed fee
Assessment vacated$51,000
Supporting recordsNow on file
AccountCleared
The situation
A Canadian corporation with US customers in Toronto, Ontario was carrying $51,000 of penalties and interest arising from 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net, much of it accumulated during a period the CRA itself had delayed.
What we did
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused and framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result
The assessment was vacated. $51,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
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.
