6 Transfer Pricing Benchmarking 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 transfer pricing benchmarking work, not a general example.
Case Study 1 · Scaling without breaking
Second-Province Expansion Handled, $55,000 Of Cash Released — Emigrant Who Left Canada, Winnipeg
Client: An emigrant who left Canada mid-year · Where: Winnipeg, Manitoba · Engagement: 5 weeks, fixed fee
Cash released$55,000
New registrationsComplete on day one
Compliance gapsNone
The situation
Revenue at an emigrant who left Canada mid-year in Winnipeg, Manitoba was up sharply and cash was tighter than ever. Underneath it sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
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
$55,000 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 · Backlog brought current
3 Years Filed, $37,000 Removed From The Assessed Balance — Canadian Resident with a, Moncton
Client: A Canadian resident with a US rental property · Where: Moncton, New Brunswick · Engagement: 7 weeks, fixed fee
Years filed3
Assessed balance removed$37,000
CollectionsStopped
The situation
A Canadian resident with a US rental property in Moncton, New Brunswick had not filed for 3 years. The CRA had issued arbitrary assessments, and the business was carrying a departure year filed as a normal resident return with no deemed disposition reported on top of a growing interest balance.
What we did
We started with the oldest year and worked forward so each year's closing balances fed the next. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, filing the years in sequence rather than all at once.
The result
Every year is now filed and assessed on actual figures. The notional assessments were vacated and $37,000 of the estimated balance came off, with a payment arrangement covering the rest.
Client: A non-resident owning Canadian rental property · Where: Surrey, British Columbia · Engagement: 9 weeks, fixed fee
Amount recovered$118,000
Reporting statusCurrent
Annual effortHours, not weeks
The situation
Foreign holdings at a non-resident owning Canadian rental property in Surrey, British Columbia 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 filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, 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 $118,000 was recovered. Reporting is now current and the annual process takes hours rather than weeks.
Case Study 4 · Deadline rescue
$38,000 Late-Filing Penalty Cancelled On Relief Application — Inbound Transferee on Assignment, Kelowna
Client: An inbound transferee on assignment · Where: Kelowna, British Columbia · Engagement: 10 weeks, fixed fee
Penalty cancelled$38,000
Relief applicationGranted
ReturnAccepted as filed
The situation
An inbound transferee on assignment in Kelowna, British Columbia had already missed one deadline and was about to miss a second. Behind it sat foreign accounts that had passed the $100,000 T1135 threshold three years earlier, and a penalty of $38,000 was accruing.
What we did
We split the work into what had to happen before the deadline and what could follow it, then reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.
The result
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $38,000 of the penalty already assessed on the earlier year.
Case Study 5 · Sale and succession
Share Sale Restructured, $275,000 Less Tax On Closing — Canadian Corporation with US, Saskatoon
Client: A Canadian corporation with US customers · Where: Saskatoon, Saskatchewan · Engagement: 4 weeks, fixed fee
Tax saved on closing$275,000
PriceAs agreed
Post-closing adjustmentsNone
The situation
A Canadian corporation with US customers in Saskatoon, Saskatchewan was preparing to sell. Due diligence surfaced a single shareholder holding every share, with no room to multiply the exemption, which would have reduced the price or killed the deal outright.
What we did
We cleaned up the historical file, filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, and prepared the due-diligence package the buyer's advisers actually asked for.
The result
The deal closed at the agreed price. $275,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.
Case Study 6 · Planning that cut the bill
$24,500 Saved By Correcting What Prior Filings Had Missed — Canadian with a US, Lethbridge
Client: A Canadian with a US employer · Where: Lethbridge, Alberta · Engagement: 3 weeks, fixed fee
Saving identified$24,500
RecurringYes
Positions documentedAll
The situation
A Canadian with a US employer in Lethbridge, Alberta asked for a second opinion on transfer pricing benchmarking after three years of rising tax. The review found 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
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 $24,500, with the same benefit recurring. Every position taken is documented and supported in the file.
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.
