6 Transfer Pricing Services 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 services work, not a general example.
Case Study 1 · Cross-border exposure resolved
$21,500 Of Excess Withholding Refunded On Election — US Citizen Living in, Hamilton
Client: A US citizen living in Canada · Where: Hamilton, Ontario · Engagement: 3 weeks, fixed fee
Withholding refunded$21,500
ElectionFiled and accepted
Cross-border reportingConsistent
The situation
A US citizen living in Canada in Hamilton, Ontario was paying tax in two countries on one stream of income, because 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net had never been reviewed against the treaty.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward and coordinated the timing so the credit claimed in Canada matched the tax actually paid abroad.
The result
$21,500 of excess withholding was refunded and the exposure closed. Both sides of the border now report consistently, which is what keeps the credit claimable.
Case Study 2 · Planning that cut the bill
$70,000 Saved By Correcting What Prior Filings Had Missed — Snowbird Spending Winters in, Ottawa
Client: A snowbird spending winters in Arizona · Where: Ottawa, Ontario · Engagement: 7 weeks, fixed fee
Saving identified$70,000
RecurringYes
Positions documentedAll
The situation
A snowbird spending winters in Arizona in Ottawa, Ontario asked for a second opinion on transfer pricing services after three years of rising tax. The review found US tax paid but no foreign tax credit claimed on the Canadian return.
What we did
We built the comparison first — current structure against two alternatives — and then reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.
The result
First-year saving of $70,000, with the same benefit recurring. Every position taken is documented and supported in the file.
Case Study 3 · Objection and relief
Notice Of Objection Allowed In Full, $113,000 Reversed — Dual Citizen with a, Mississauga
Client: A dual citizen with a US retirement account · Where: Mississauga, Ontario · Engagement: 4 weeks, fixed fee
Amount reversed$113,000
ObjectionAllowed in full
Account balanceNil
The situation
A dual citizen with a US retirement account in Mississauga, Ontario had been reassessed for $113,000 and had 7 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 filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund.
The result
The appeals officer allowed the objection in full. $113,000 was reversed and the account returned to a nil balance.
Case Study 4 · Structure rebuilt
Corporate Structure Rebuilt For $34,000 Of Annual Savings — Canadian with a US, Calgary
Client: A Canadian with a US employer · Where: Calgary, Alberta · Engagement: 6 weeks, fixed fee
Saving per year$34,000
DocumentationComplete
Transfer basisRollover
The situation
The structure at a Canadian with a US employer in Calgary, Alberta had been set up years earlier for a business that no longer existed, and a departure year filed as a normal resident return with no deemed disposition reported had become expensive.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result
$34,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 5 · CRA review defended
Audit Defence Closed In 3 Weeks, $34,000 Cleared — Shareholder of a US, Lethbridge
Client: A shareholder of a US LLC · Where: Lethbridge, Alberta · Engagement: 3 weeks, fixed fee
Proposed tax cleared$34,000
Review duration3 weeks
OutcomeNo change
The situation
A shareholder of a US LLC in Lethbridge, Alberta was selected for review after foreign accounts that had passed the $100,000 T1135 threshold three years earlier showed up in the CRA's automated matching. The proposed adjustment on transfer pricing services came to $34,000.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. Every figure in the response traced to a source record the auditor could verify without asking a second question.
The result
The review closed with no change. $34,000 of proposed tax came off the table, and the documentation now in place makes the next review a short one.
Case Study 6 · Scaling without breaking
Scaled To 90 Staff With $150,000 Of Working Capital Freed — Canadian Corporation with US, Kelowna
Client: A Canadian corporation with US customers · Where: Kelowna, British Columbia · Engagement: 10 weeks, fixed fee
Headcount reached90
Working capital freed$150,000
Missed deadlinesZero
The situation
A Canadian corporation with US customers in Kelowna, British Columbia was growing fast — headcount to 90 in eighteen months — and the back office had not kept up. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net was the first thing to break.
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 built the compliance calendar for the size the business was becoming rather than the size it had been.
The result
The business reached 90 staff with no missed remittance and no late filing. $150,000 of working capital was freed in the process.
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.
