6 Tax Residency and Treaty Tie-Breaker Review 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 tax residency and treaty tie-breaker review work, not a general example.
Case Study 1 · Deadline rescue
11-Week Turnaround Beat The Deadline And Saved $44,000 — Snowbird Spending Winters in, Calgary
Client: A snowbird spending winters in Arizona · Where: Calgary, Alberta · Engagement: 11 weeks, fixed fee
Late-filing penalty avoided$44,000
Filed with8 days to spare
Next yearPapers ready
The situation
With the deadline for tax residency and treaty tie-breaker review weeks away, a snowbird spending winters in Arizona in Calgary, Alberta was carrying US tax paid but no foreign tax credit claimed on the Canadian return. The exposure if the date slipped was around $44,000.
What we did
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. The filing went in complete rather than provisional, so there was no amended return to follow.
The result
Filed with 8 days to spare. $44,000 in late-filing penalties avoided, and the working papers are ready for the following year.
Case Study 2 · Planning that cut the bill
$45,000 Saved By Correcting What Prior Filings Had Missed — Inbound Transferee on Assignment, Edmonton
Client: An inbound transferee on assignment · Where: Edmonton, Alberta · Engagement: 10 weeks, fixed fee
Saving identified$45,000
RecurringYes
Positions documentedAll
The situation
An inbound transferee on assignment in Edmonton, Alberta asked for a second opinion on tax residency and treaty tie-breaker review after three years of rising tax. The review found a departure year filed as a normal resident return with no deemed disposition reported.
What we did
We built the comparison first — current structure against two alternatives — and then restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward.
The result
First-year saving of $45,000, with the same benefit recurring. Every position taken is documented and supported in the file.
Case Study 3 · Missed incentive claimed
Incentive Review Recovered $30,500 Across 7 Open Years — Non-Resident Owning Canadian Rental, Hamilton
Client: A non-resident owning Canadian rental property · Where: Hamilton, Ontario · Engagement: 5 weeks, fixed fee
Recovered$30,500
Open years claimed7
Ongoing trackingIn place
The situation
An incentive review at a non-resident owning Canadian rental property in Hamilton, Ontario started from a simple question: what has never been claimed? The answer ran to 7 years, driven by a US LLC taxed as a corporation in Canada, producing double tax on the same income.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, documenting eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result
The credits produced $30,500 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 · Structure rebuilt
Corporate Structure Rebuilt For $51,000 Of Annual Savings — Shareholder of a US, Saskatoon
Client: A shareholder of a US LLC · Where: Saskatoon, Saskatchewan · Engagement: 5 weeks, fixed fee
Saving per year$51,000
DocumentationComplete
Transfer basisRollover
The situation
The structure at a shareholder of a US LLC in Saskatoon, Saskatchewan had been set up years earlier for a business that no longer existed, and a US LLC taxed as a corporation in Canada, producing double tax on the same income had become expensive.
What we did
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result
$51,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 5 · Records and systems rebuilt
9 Months Reconciled And $7,500 Of Input Tax Recovered — Dual Citizen with a, Brampton
Client: A dual citizen with a US retirement account · Where: Brampton, Ontario · Engagement: 11 weeks, fixed fee
Months reconciled9
Input tax recovered$7,500
Close time6 days
The situation
A dual citizen with a US retirement account in Brampton, Ontario was carrying foreign accounts that had passed the $100,000 T1135 threshold three years earlier. Nothing reconciled, and every filing started with 9 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
9 months reconciled to the bank. The close now takes 6 days, and $7,500 of previously unclaimable input tax was recovered in the process.
Case Study 6 · Scaling without breaking
Growth Handled Without A Missed Filing, $137,000 Freed — Canadian Resident with a, Red Deer
Client: A Canadian resident with a US rental property · Where: Red Deer, Alberta · Engagement: 7 weeks, fixed fee
Cash freed$137,000
Compliance failuresNone
ReportingMonthly
The situation
A Canadian resident with a US rental property in Red Deer, Alberta was opening in a second province — different filing obligations, a different payroll regime, and US tax paid but no foreign tax credit claimed on the Canadian return already in the file.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward 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. $137,000 of cash was released, and the monthly reporting now flags a problem while it is still small.
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.
