6 Transfer Pricing Documentation 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 documentation work, not a general example.
Case Study 1 · Missed incentive claimed
$40,000 In Credits Claimed That Prior Filings Had Missed — US Citizen Living in, Kitchener
Client: A US citizen living in Canada · Where: Kitchener, Ontario · Engagement: 11 weeks, fixed fee
Credits claimed$40,000
Years adjusted6
Review outcomeNo adjustment
The situation
A US citizen living in Canada in Kitchener, Ontario had been filing for 6 years without ever claiming the incentives its activity qualified for. Behind that sat a US LLC taxed as a corporation in Canada, producing double tax on the same income.
What we did
We tested each activity against the eligibility criteria rather than the description on the invoice, then restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward.
The result
$40,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 2 · Scaling without breaking
Growth Handled Without A Missed Filing, $160,000 Freed — Dual Citizen with a, Edmonton
Client: A dual citizen with a US retirement account · Where: Edmonton, Alberta · Engagement: 4 weeks, fixed fee
Cash freed$160,000
Compliance failuresNone
ReportingMonthly
The situation
A dual citizen with a US retirement account in Edmonton, 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 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. $160,000 of cash was released, and the monthly reporting now flags a problem while it is still small.
Case Study 3 · Objection and relief
Desk-Review Assessment Of $70,000 Vacated — Shareholder of a US, Victoria
Client: A shareholder of a US LLC · Where: Victoria, British Columbia · Engagement: 3 weeks, fixed fee
Assessment vacated$70,000
Supporting recordsNow on file
AccountCleared
The situation
A shareholder of a US LLC in Victoria, British Columbia was carrying $70,000 of penalties and interest arising from a US LLC taxed as a corporation in Canada, producing double tax on the same income, much of it accumulated during a period the CRA itself had delayed.
What we did
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused and framed the relief application on the specific grounds the CRA guidelines recognise rather than on general hardship.
The result
The assessment was vacated. $70,000 came off the account, and the documentation now on file makes the same position straightforward to defend next time.
Case Study 4 · Backlog brought current
Collections Halted And $17,000 Cut From A 3-Year Backlog — Snowbird Spending Winters in, Winnipeg
Client: A snowbird spending winters in Arizona · Where: Winnipeg, Manitoba · Engagement: 3 weeks, fixed fee
Balance reduced by$17,000
Backlog cleared3 years
CollectionsHalted
The situation
By the time a snowbird spending winters in Arizona in Winnipeg, Manitoba called, 3 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 filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. 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 $17,000, and a relief application addressed part of the accumulated interest.
Case Study 5 · Structure rebuilt
Corporate Structure Rebuilt For $29,000 Of Annual Savings — Canadian with a US, Moncton
Client: A Canadian with a US employer · Where: Moncton, New Brunswick · Engagement: 9 weeks, fixed fee
Saving per year$29,000
DocumentationComplete
Transfer basisRollover
The situation
The structure at a Canadian with a US employer in Moncton, New Brunswick had been set up years earlier for a business that no longer existed, and foreign accounts that had passed the $100,000 T1135 threshold three years earlier had become expensive.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result
$29,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 6 · Cross-border exposure resolved
$142,000 Of Double Taxation Removed On Treaty Position — Canadian Corporation with US, Surrey
Client: A Canadian corporation with US customers · Where: Surrey, British Columbia · Engagement: 10 weeks, fixed fee
Double tax removed$142,000
DisclosureBrought current
Penalty exposureEliminated
The situation
A Canadian corporation with US customers in Surrey, British Columbia had US-side activity that the Canadian filings had never addressed. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net meant the same income was being taxed twice.
What we did
We established the residency and source position first, then filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund so the Canadian and foreign filings finally told the same story.
The result
$142,000 of double taxation was removed, the disclosure obligations were brought current, and the penalty exposure was eliminated through the voluntary route.
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.
