6 Section 216 Non-Resident Rental Return 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 216 non-resident rental return work, not a general example.
Case Study 1 · Scaling without breaking
Scaled To 70 Staff With $29,500 Of Working Capital Freed — Non-Resident Owning Canadian Rental, Winnipeg
Client: A non-resident owning Canadian rental property · Where: Winnipeg, Manitoba · Engagement: 8 weeks, fixed fee
Headcount reached70
Working capital freed$29,500
Missed deadlinesZero
The situation
A non-resident owning Canadian rental property in Winnipeg, Manitoba was growing fast — headcount to 70 in eighteen months — and the back office had not kept up. Foreign accounts that had passed the $100,000 T1135 threshold three years earlier was the first thing to break.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, and built the compliance calendar for the size the business was becoming rather than the size it had been.
The result
The business reached 70 staff with no missed remittance and no late filing. $29,500 of working capital was freed in the process.
Case Study 2 · Sale and succession
Intergenerational Transfer Completed With $595,000 Deferred — US Citizen Living in, Calgary
Client: A US citizen living in Canada · Where: Calgary, Alberta · Engagement: 5 weeks, fixed fee
Tax deferred$595,000
TransferCompleted
RecordsReview-ready
The situation
A generational transfer at a US citizen living in Canada in Calgary, Alberta had been discussed for years without a plan. No valuation on file to support the price the parties had agreed meant the transfer as contemplated would have been fully taxable.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, sequencing the steps so each one was complete and documented before the next depended on it.
The result
$595,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
Case Study 3 · Cash and remittance control
Instalments Rebased, $41,000 Of Cash Returned To The Business — Inbound Transferee on Assignment, Barrie
Client: An inbound transferee on assignment · Where: Barrie, Ontario · Engagement: 10 weeks, fixed fee
Cash returned$41,000
Instalment basisCurrent year
ReviewedQuarterly
The situation
An inbound transferee on assignment in Barrie, Ontario was paying instalments calculated on a prior year that no longer reflected the business. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net was tying up $41,000 of cash.
What we did
We rebased the instalments on the current-year estimate rather than the prior-year default, and filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund.
The result
$41,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.
Case Study 4 · Backlog brought current
Collections Halted And $80,000 Cut From A 5-Year Backlog — Dual Citizen with a, Kitchener
Client: A dual citizen with a US retirement account · Where: Kitchener, Ontario · Engagement: 10 weeks, fixed fee
Balance reduced by$80,000
Backlog cleared5 years
CollectionsHalted
The situation
By the time a dual citizen with a US retirement account in Kitchener, Ontario called, 5 years were outstanding and the CRA had assessed on estimates. Underneath it sat a departure year filed as a normal resident return with no deemed disposition reported.
What we did
We reconstructed the records year by year and reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. 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 $80,000, and a relief application addressed part of the accumulated interest.
Case Study 5 · Planning that cut the bill
$26,500 Cut From The Annual Tax Bill — Canadian Corporation with US, Saskatoon
Client: A Canadian corporation with US customers · Where: Saskatoon, Saskatchewan · Engagement: 8 weeks, fixed fee
First-year saving$26,500
RepeatsAnnually
Filing positionUnchanged in risk
The situation
A Canadian corporation with US customers in Saskatoon, Saskatchewan was compliant but paying more than it needed to. The prior year had been filed correctly and still left US tax paid but no foreign tax credit claimed on the Canadian return on the table.
What we did
We modelled the current position against the alternatives before changing anything, then filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely.
The result
The change saved $26,500 in the first year and repeats annually. Nothing about the filings became more aggressive; the position is simply the one the rules already allowed.
Case Study 6 · Structure rebuilt
Reorganisation Completed Tax-Deferred, $37,000 Saved Each Year — Shareholder of a US, Ottawa
Client: A shareholder of a US LLC · Where: Ottawa, Ontario · Engagement: 4 weeks, fixed fee
Annual saving$37,000
Tax on reorganisationDeferred
Elections filedOn time
The situation
A shareholder of a US LLC in Ottawa, Ontario had outgrown the structure it started with. Foreign accounts that had passed the $100,000 T1135 threshold three years earlier was the immediate problem; the longer-term one was that the structure blocked the next step.
What we did
We mapped the current structure, modelled the target, and restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward — with the tax-deferred elections filed on time and the supporting valuations documented.
The result
The reorganisation completed without triggering tax, and the new structure saves approximately $37,000 a year while removing the exposure the old one carried.
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.
