6 Transfer Pricing Functional Analysis 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 functional analysis work, not a general example.
Case Study 1 · Missed incentive claimed
$47,000 In Credits Claimed That Prior Filings Had Missed — US Citizen Living in, Mississauga
Client: A US citizen living in Canada · Where: Mississauga, Ontario · Engagement: 7 weeks, fixed fee
Credits claimed$47,000
Years adjusted4
Review outcomeNo adjustment
The situation
A US citizen living in Canada in Mississauga, Ontario had been filing for 4 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
$47,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 2 · Scaling without breaking
Second-Province Expansion Handled, $77,000 Of Cash Released — Inbound Transferee on Assignment, Brampton
Client: An inbound transferee on assignment · Where: Brampton, Ontario · Engagement: 5 weeks, fixed fee
Cash released$77,000
New registrationsComplete on day one
Compliance gapsNone
The situation
Revenue at an inbound transferee on assignment in Brampton, Ontario was up sharply and cash was tighter than ever. Underneath it 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. Every new obligation — registration, remittance frequency, provincial filing — was set up before it was triggered, not after.
The result
$77,000 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 3 · Objection and relief
Notice Of Objection Allowed In Full, $11,500 Reversed — Dual Citizen with a, Lethbridge
Client: A dual citizen with a US retirement account · Where: Lethbridge, Alberta · Engagement: 8 weeks, fixed fee
Amount reversed$11,500
ObjectionAllowed in full
Account balanceNil
The situation
A dual citizen with a US retirement account in Lethbridge, Alberta had been reassessed for $11,500 and had 20 days left on the objection deadline. The reassessment rested on a US LLC taxed as a corporation in Canada, producing double tax on the same income.
What we did
We filed the objection inside the deadline with a complete submission rather than a placeholder, and reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.
The result
The appeals officer allowed the objection in full. $11,500 was reversed and the account returned to a nil balance.
Case Study 4 · Backlog brought current
7 Years Filed, $77,000 Removed From The Assessed Balance — Canadian Corporation with US, Halifax
Client: A Canadian corporation with US customers · Where: Halifax, Nova Scotia · Engagement: 7 weeks, fixed fee
Years filed7
Assessed balance removed$77,000
CollectionsStopped
The situation
A Canadian corporation with US customers in Halifax, Nova Scotia had not filed for 7 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 filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, 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 $77,000 of the estimated balance came off, with a payment arrangement covering the rest.
Case Study 5 · Structure rebuilt
Holding Structure Added, $51,000 Saved Annually — Shareholder of a US, Moncton
Client: A shareholder of a US LLC · Where: Moncton, New Brunswick · Engagement: 3 weeks, fixed fee
Annual saving$51,000
ReorganisationTax-neutral
StructureMatches operations
The situation
A shareholder of a US LLC in Moncton, New Brunswick was carrying foreign accounts that had passed the $100,000 T1135 threshold three years earlier, and every option for fixing it ran through a reorganisation that had to be done without triggering tax.
What we did
Working with the client's lawyer, we restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward and prepared the elections, resolutions and valuations the structure needed to stand up.
The result
The structure now matches the business. Annual saving of $51,000, and the reorganisation itself was tax-neutral.
Case Study 6 · Cross-border exposure resolved
Foreign Reporting Brought Current, $31,000 Recovered — Emigrant Who Left Canada, Ottawa
Client: An emigrant who left Canada mid-year · Where: Ottawa, Ontario · Engagement: 3 weeks, fixed fee
Amount recovered$31,000
Reporting statusCurrent
Annual effortHours, not weeks
The situation
Foreign holdings at an emigrant who left Canada mid-year in Ottawa, Ontario had passed the reporting threshold without anyone noticing. Behind the disclosure problem sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
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 $31,000 was recovered. Reporting is now current and the annual process takes hours rather than weeks.
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.
