6 Section 116 Certificate of Compliance 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 section 116 certificate of compliance work, not a general example.
Case Study 1 · Scaling without breaking
Second-Province Expansion Handled, $16,000 Of Cash Released — Canadian Corporation with US, Windsor
Client: A Canadian corporation with US customers · Where: Windsor, Ontario · Engagement: 11 weeks, fixed fee
Cash released$16,000
New registrationsComplete on day one
Compliance gapsNone
The situation
Revenue at a Canadian corporation with US customers in Windsor, Ontario was up sharply and cash was tighter than ever. Underneath it sat a departure year filed as a normal resident return with no deemed disposition reported.
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
$16,000 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 · Cross-border exposure resolved
$142,000 Of Excess Withholding Refunded On Election — Snowbird Spending Winters in, Kitchener
Client: A snowbird spending winters in Arizona · Where: Kitchener, Ontario · Engagement: 9 weeks, fixed fee
Withholding refunded$142,000
ElectionFiled and accepted
Cross-border reportingConsistent
The situation
A snowbird spending winters in Arizona in Kitchener, Ontario was paying tax in two countries on one stream of income, because US tax paid but no foreign tax credit claimed on the Canadian return had never been reviewed against the treaty.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward and coordinated the timing so the credit claimed in Canada matched the tax actually paid abroad.
The result
$142,000 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 3 · Sale and succession
Intergenerational Transfer Completed With $545,000 Deferred — Non-Resident Owning Canadian Rental, Burnaby
Client: A non-resident owning Canadian rental property · Where: Burnaby, British Columbia · Engagement: 6 weeks, fixed fee
Tax deferred$545,000
TransferCompleted
RecordsReview-ready
The situation
A generational transfer at a non-resident owning Canadian rental property in Burnaby, British Columbia had been discussed for years without a plan. Passive assets sitting inside the operating company, disqualifying the shares meant the transfer as contemplated would have been fully taxable.
What we did
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, sequencing the steps so each one was complete and documented before the next depended on it.
The result
$545,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
Case Study 4 · Objection and relief
$48,000 Of Penalties And Interest Cancelled On Relief — Dual Citizen with a, Halifax
Client: A dual citizen with a US retirement account · Where: Halifax, Nova Scotia · Engagement: 3 weeks, fixed fee
Penalties and interest cancelled$48,000
Relief groundsAccepted
AssessmentAdjusted to filed position
The situation
An assessment of $48,000 landed at a dual citizen with a US retirement account in Halifax, Nova Scotia following a desk review. The auditor had not seen the records behind a US LLC taxed as a corporation in Canada, producing double tax on the same income.
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 set out the legislative basis for the position alongside the documents supporting it.
The result
$48,000 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.
Case Study 5 · Cash and remittance control
$149,000 Of Working Capital Freed From The Tax Cycle — Emigrant Who Left Canada, Winnipeg
Client: An emigrant who left Canada mid-year · Where: Winnipeg, Manitoba · Engagement: 7 weeks, fixed fee
Working capital freed$149,000
On-time remittancesEvery period since
Forecast horizon13 weeks
The situation
An emigrant who left Canada mid-year in Winnipeg, Manitoba was profitable on paper and short of cash every month. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net explained most of the gap.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely and built a thirteen-week cash view so tax payments stopped competing with payroll for the same dollars.
The result
$149,000 was released back into working capital. Remittances have been on time every period since, and the forecast shows the tax outflow before it lands.
Case Study 6 · CRA review defended
Audit Defence Closed In 3 Weeks, $84,000 Cleared — Canadian with a US, Mississauga
Client: A Canadian with a US employer · Where: Mississauga, Ontario · Engagement: 3 weeks, fixed fee
Proposed tax cleared$84,000
Review duration3 weeks
OutcomeNo change
The situation
A Canadian with a US employer in Mississauga, Ontario was selected for review after a departure year filed as a normal resident return with no deemed disposition reported showed up in the CRA's automated matching. The proposed adjustment on section 116 certificate of compliance came to $84,000.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. Every figure in the response traced to a source record the auditor could verify without asking a second question.
The result
The review closed with no change. $84,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.
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.
