T1135 Foreign Income Verification Statement Case Studies

6 T1135 Foreign Income Verification Statement 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 t1135 foreign income verification statement work, not a general example.

Case Study 1 · Objection and relief

Notice Of Objection Allowed In Full, $126,000 Reversed — Dual Citizen with a, Halifax

Client: A dual citizen with a US retirement account  ·  Where: Halifax, Nova Scotia  ·  Engagement: 8 weeks, fixed fee

Amount reversed$126,000
ObjectionAllowed in full
Account balanceNil

The situation

A dual citizen with a US retirement account in Halifax, Nova Scotia had been reassessed for $126,000 and had 9 days left on the objection deadline. The reassessment rested on a US LLC taxed as a corporation in Canada, producing double tax on the same income.

What we did

We filed the objection inside the deadline with a complete submission rather than a placeholder, and reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.

The result

The appeals officer allowed the objection in full. $126,000 was reversed and the account returned to a nil balance.

Case Study 2 · Sale and succession

Intergenerational Transfer Completed With $800,000 Deferred — Emigrant Who Left Canada, Moncton

Client: An emigrant who left Canada mid-year  ·  Where: Moncton, New Brunswick  ·  Engagement: 6 weeks, fixed fee

Tax deferred$800,000
TransferCompleted
RecordsReview-ready

The situation

A generational transfer at an emigrant who left Canada mid-year in Moncton, New Brunswick had been discussed for years without a plan. A shareholder loan balance that would have been picked up as income on closing meant the transfer as contemplated would have been fully taxable.

What we did

We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, sequencing the steps so each one was complete and documented before the next depended on it.

The result

$800,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.

Case Study 3 · Cross-border exposure resolved

Foreign Reporting Brought Current, $126,000 Recovered — Canadian with a US, Ottawa

Client: A Canadian with a US employer  ·  Where: Ottawa, Ontario  ·  Engagement: 5 weeks, fixed fee

Amount recovered$126,000
Reporting statusCurrent
Annual effortHours, not weeks

The situation

Foreign holdings at a Canadian with a US employer in Ottawa, Ontario had passed the reporting threshold without anyone noticing. Behind the disclosure problem sat US tax paid but no foreign tax credit claimed on the Canadian return.

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 $126,000 was recovered. Reporting is now current and the annual process takes hours rather than weeks.

Case Study 4 · Scaling without breaking

Growth Handled Without A Missed Filing, $27,000 Freed — Inbound Transferee on Assignment, Kitchener

Client: An inbound transferee on assignment  ·  Where: Kitchener, Ontario  ·  Engagement: 3 weeks, fixed fee

Cash freed$27,000
Compliance failuresNone
ReportingMonthly

The situation

An inbound transferee on assignment in Kitchener, Ontario was opening in a second province — different filing obligations, a different payroll regime, and a departure year filed as a normal resident return with no deemed disposition reported already in the file.

What we did

We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund and put monthly reporting in place so the owner could see the cash effect of growth while there was still time to act on it.

The result

Growth was absorbed without a compliance failure. $27,000 of cash was released, and the monthly reporting now flags a problem while it is still small.

Case Study 5 · Records and systems rebuilt

27 Months Reconciled And $7,500 Of Input Tax Recovered — Shareholder of a US, Calgary

Client: A shareholder of a US LLC  ·  Where: Calgary, Alberta  ·  Engagement: 10 weeks, fixed fee

Months reconciled27
Input tax recovered$7,500
Close time9 days

The situation

A shareholder of a US LLC in Calgary, Alberta was carrying 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. Nothing reconciled, and every filing started with 27 months of cleanup.

What we did

We rebuilt from source rather than correcting on top of the existing file. We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused, then set the routine that keeps it clean.

The result

27 months reconciled to the bank. The close now takes 9 days, and $7,500 of previously unclaimable input tax was recovered in the process.

Case Study 6 · Structure rebuilt

Holding Structure Added, $35,000 Saved Annually — Canadian Resident with a, London

Client: A Canadian resident with a US rental property  ·  Where: London, Ontario  ·  Engagement: 4 weeks, fixed fee

Annual saving$35,000
ReorganisationTax-neutral
StructureMatches operations

The situation

A Canadian resident with a US rental property in London, Ontario was carrying a US LLC taxed as a corporation in Canada, producing double tax on the same income, and every option for fixing it ran through a reorganisation that had to be done without triggering tax.

What we did

Working with the client's lawyer, we filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely and prepared the elections, resolutions and valuations the structure needed to stand up.

The result

The structure now matches the business. Annual saving of $35,000, and the reorganisation itself was tax-neutral.

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.

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