6 worked Transfer Pricing Documentation 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 transfer pricing documentation work, not a specific client's file.
Case Study 1 · Missed incentive claimed
$40,000 In Credits Claimed That Prior Filings Had Missed — US Pension Recipient, Kitchener
Client: A Canadian resident receiving US pension income · Where: Kitchener, Ontario · Engagement: 11 weeks, fixed fee
Credits claimed$40,000
Years adjusted6
Review outcomeNo adjustment
The situation — A Canadian resident receiving US pension income, Kitchener, Ontario
A Canadian resident receiving US pension income 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 for A Canadian resident receiving US pension income, Kitchener, Ontario
We tested each activity against the eligibility criteria rather than the description on the invoice, then applied the treaty rate to the dividend withholding, filed the NR4 return, and remitted the shortfall before the CRA assessed the payer for it.
The result — A Canadian resident receiving US pension income, Kitchener, Ontario
$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 — Inbound Assignee, Edmonton
Client: An inbound transferee on assignment · Where: Edmonton, Alberta · Engagement: 4 weeks, fixed fee
Cash freed$160,000
Compliance failuresNone
ReportingMonthly
The situation — An inbound transferee on assignment, Edmonton, Alberta
An inbound transferee on assignment in Edmonton, Alberta was opening in a second province — different filing obligations, a different payroll regime, and 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net already in the file.
What we did for An inbound transferee on assignment, Edmonton, Alberta
We registered the payer for a non-resident withholding account, remitted the Regulation 105 amounts due, and applied for waivers covering the rest of the contract 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 — An inbound transferee on assignment, Edmonton, Alberta
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 — Arizona Snowbird, Victoria
Client: A snowbird spending winters in Arizona · Where: Victoria, British Columbia · Engagement: 3 weeks, fixed fee
Assessment vacated$70,000
Supporting recordsNow on file
AccountCleared
The situation — A snowbird spending winters in Arizona, Victoria, British Columbia
A snowbird spending winters in Arizona in Victoria, British Columbia was carrying $70,000 of penalties and interest arising from winters spent in the United States with the day count kept casually and no residency position documented anywhere, much of it accumulated during a period the CRA itself had delayed.
What we did for A snowbird spending winters in Arizona, Victoria, British Columbia
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 — A snowbird spending winters in Arizona, Victoria, British Columbia
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 — Florida Property Owner, Winnipeg
Client: A family with a Florida vacation property · Where: Winnipeg, Manitoba · Engagement: 3 weeks, fixed fee
Balance reduced by$17,000
Backlog cleared3 years
CollectionsHalted
The situation — A family with a Florida vacation property, Winnipeg, Manitoba
By the time a family with a Florida vacation property in Winnipeg, Manitoba called, 3 years were outstanding and the CRA had assessed on estimates. Underneath it sat US tax paid but no foreign tax credit claimed on the Canadian return.
What we did for A family with a Florida vacation property, Winnipeg, Manitoba
We reconstructed the records year by year and filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. Each filing replaced an arbitrary assessment with a real one.
The result — A family with a Florida vacation property, Winnipeg, Manitoba
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 on US Payroll, 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 — A Canadian with a US employer, Moncton, New Brunswick
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 a US LLC taxed as a corporation in Canada, producing double tax on the same income had become expensive.
What we did for A Canadian with a US employer, Moncton, New Brunswick
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 — A Canadian with a US employer, Moncton, New Brunswick
$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 — US-Facing Canadian Corporation, 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, Surrey, British Columbia
A Canadian corporation with US customers in Surrey, British Columbia had US-side activity that the Canadian filings had never addressed. Dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability meant the same income was being taxed twice.
What we did for A Canadian corporation with US customers, Surrey, British Columbia
We established the residency and source position first, then filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely so the Canadian and foreign filings finally told the same story.
The result — A Canadian corporation with US customers, Surrey, British Columbia
$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, Founder and Tax Accountant. 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.
