T4A-NR Preparation Case Studies

6 worked T4A-NR Preparation 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 t4a-nr preparation work, not a specific client's file.

Case Study 1 · Cash and remittance control

Remittance Schedule Corrected, $104,000 Refunded — Long-Stay Visitor, Guelph

Client: A long-stay visitor to Canada  ·  Where: Guelph, Ontario  ·  Engagement: 8 weeks, fixed fee

Overpayment refunded$104,000
Late remittances sinceZero
ScheduleAutomated

The situation — A long-stay visitor to Canada, Guelph, Ontario

Remittances at a long-stay visitor to Canada in Guelph, Ontario were consistently late by a few days. That was enough to trigger penalties every quarter. Behind it sat a departure year filed as an ordinary resident return, with no deemed disposition reported and no list of the properties owned on the departure date.

What we did for A long-stay visitor to Canada, Guelph, Ontario

We reported the deemed disposition on the return for the year residency ended. We elected to defer the tax against acceptable security, so nothing was payable until the property was actually sold. Then we moved the remittance dates into a scheduled process rather than a monthly decision.

The result — A long-stay visitor to Canada, Guelph, Ontario

Penalties stopped from the following remittance onwards, and $104,000 of overpaid instalments was refunded.

Case Study 2 · Records and systems rebuilt

Books Rebuilt From Source, $17,000 In Unclaimed Input Tax Found — First-Year Resident, Kitchener

Client: A first-year Canadian resident  ·  Where: Kitchener, Ontario  ·  Engagement: 7 weeks, fixed fee

Unclaimed tax found$17,000
Records rebuilt33 months
ProcessDocumented

The situation — A first-year Canadian resident, Kitchener, Ontario

A first-year Canadian resident in Kitchener, Ontario could not answer basic questions about its own numbers. An arrival year reported from January rather than from the date residency actually began sat between the bank statements and the ledger.

What we did for A first-year Canadian resident, Kitchener, Ontario

We corrected the foreign property reporting from the first year it was actually required, using the voluntary route before the CRA raised it. We then documented the process so the work does not depend on any one person remembering how it was done.

The result — A first-year Canadian resident, Kitchener, Ontario

Records rebuilt and reconciled, $17,000 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.

Case Study 3 · Backlog brought current

$134,000 Of Arbitrary Assessments Vacated After 3 Years — Newcomer with Foreign Property, Surrey

Client: A newcomer holding foreign property  ·  Where: Surrey, British Columbia  ·  Engagement: 9 weeks, fixed fee

Arbitrary tax vacated$134,000
Years brought current3
Account statusCurrent

The situation — A newcomer holding foreign property, Surrey, British Columbia

3 years of unfiled returns had turned into notional assessments at a newcomer holding foreign property in Surrey, British Columbia. Underneath lay rent remitted abroad in full by a Canadian agent who had never been told the withholding was their obligation. Collections had already started.

What we did for A newcomer holding foreign property, Surrey, British Columbia

We put an NR6 undertaking in place with the Canadian agent so the following year was withheld on estimated net rent rather than on gross. We then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.

The result — A newcomer holding foreign property, Surrey, British Columbia

All 3 years were accepted as filed. $134,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 3 years.

Case Study 4 · Cross-border exposure resolved

Foreign Reporting Brought Current, $64,000 Recovered — Dual-Resident Professional, Calgary

Client: A dual-resident professional  ·  Where: Calgary, Alberta  ·  Engagement: 9 weeks, fixed fee

Amount recovered$64,000
Reporting statusCurrent
Annual effortHours, not weeks

The situation — A dual-resident professional, Calgary, Alberta

Foreign holdings at a dual-resident professional in Calgary, Alberta had passed the reporting threshold without anyone noticing. Behind the disclosure problem sat a T1135 filed for the year of arrival, when none was required, and none filed for the years that followed.

What we did for A dual-resident professional, Calgary, Alberta

We filed the notification of disposition and obtained the clearance certificate. We released the proceeds the purchaser had been holding against a withholding calculated on the gross price. We claimed the treaty relief and foreign tax credits on the Canadian return and corrected the disclosure position for the open years.

The result — A dual-resident professional, Calgary, Alberta

The treaty position was accepted and $64,000 was recovered. Reporting is now current and the annual process takes hours rather than weeks.

Case Study 5 · Planning that cut the bill

Remuneration Review Saved $46,000 Across Corporate And Personal Returns — Non-Resident Residential Landlord, Windsor

Client: A non-resident residential landlord  ·  Where: Windsor, Ontario  ·  Engagement: 9 weeks, fixed fee

Combined saving$46,000
ScopeCorporate + personal
Future yearsNo rework needed

The situation — A non-resident residential landlord, Windsor, Ontario

Nothing was wrong at a non-resident residential landlord in Windsor, Ontario. The filings were on time and accurate. What they were not was planned. More than half the year spent in Canada on visits while the returns continued to be filed as a non-resident had never been reviewed.

What we did for A non-resident residential landlord, Windsor, Ontario

We mapped the residential ties on each side of the departure date and fixed the date residency actually ceased. We filed the emigrant return with the deemed disposition and the property list built on that date. 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 non-resident residential landlord, Windsor, Ontario

$46,000 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.

Case Study 6 · Objection and relief

$90,000 Of Penalties And Interest Cancelled On Relief — Non-Resident Performer, London

Client: A non-resident performer working in Canada  ·  Where: London, Ontario  ·  Engagement: 11 weeks, fixed fee

Penalties and interest cancelled$90,000
Relief groundsAccepted
AssessmentAdjusted to filed position

The situation — A non-resident performer working in Canada, London, Ontario

An assessment of $90,000 landed at a non-resident performer working in Canada in London, Ontario following a desk review. It turned on registered plan withdrawals taken after departure at the flat non-resident rate with no election ever considered. The auditor had not seen the records behind it.

What we did for A non-resident performer working in Canada, London, Ontario

We split the year at the residency date and prorated the personal credits to the days of residency. We refiled the years that had claimed the full amounts. We then set out the legislative basis for the position alongside the documents supporting it.

The result — A non-resident performer working in Canada, London, Ontario

$90,000 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.

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.

Sources. CRA — Payroll · CRA — Keeping records · Income Tax Act (Justice Laws Website)

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