6 worked Transfer Pricing Services 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 services work, not a specific client's file.
Case Study 1 · Cross-border exposure resolved
$21,500 Of Excess Withholding Refunded On Election — Arizona Snowbird, Hamilton
Client: A snowbird spending winters in Arizona · Where: Hamilton, Ontario · Engagement: 3 weeks, fixed fee
Withholding refunded$21,500
ElectionFiled and accepted
Cross-border reportingConsistent
The situation — A snowbird spending winters in Arizona, Hamilton, Ontario
A snowbird spending winters in Arizona in Hamilton, Ontario was paying tax in two countries on one stream of income, because invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken had never been reviewed against the treaty.
What we did for A snowbird spending winters in Arizona, Hamilton, Ontario
We applied the treaty rate to the dividend withholding, filed the NR4 return, and remitted the shortfall before the CRA assessed the payer for it and coordinated the timing so the credit claimed in Canada matched the tax actually paid abroad.
The result — A snowbird spending winters in Arizona, Hamilton, Ontario
$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 — Inbound Assignee, Ottawa
Client: An inbound transferee on assignment · Where: Ottawa, Ontario · Engagement: 7 weeks, fixed fee
Saving identified$70,000
RecurringYes
Positions documentedAll
The situation — An inbound transferee on assignment, Ottawa, Ontario
An inbound transferee on assignment in Ottawa, Ontario asked for a second opinion on transfer pricing services after three years of rising tax. The review found winters spent in the United States with the day count kept casually and no residency position documented anywhere.
What we did for An inbound transferee on assignment, Ottawa, Ontario
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 — An inbound transferee on assignment, Ottawa, Ontario
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 — US Pension Recipient, Mississauga
Client: A Canadian resident receiving US pension income · Where: Mississauga, Ontario · Engagement: 4 weeks, fixed fee
Amount reversed$113,000
ObjectionAllowed in full
Account balanceNil
The situation — A Canadian resident receiving US pension income, Mississauga, Ontario
A Canadian resident receiving US pension income 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 for A Canadian resident receiving US pension income, Mississauga, Ontario
We filed the objection inside the deadline with a complete submission rather than a placeholder, and reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked.
The result — A Canadian resident receiving US pension income, Mississauga, Ontario
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 — Non-Resident Landlord, Calgary
Client: A non-resident owning Canadian rental property · Where: Calgary, Alberta · Engagement: 6 weeks, fixed fee
Saving per year$34,000
DocumentationComplete
Transfer basisRollover
The situation — A non-resident owning Canadian rental property, Calgary, Alberta
The structure at a non-resident owning Canadian rental property 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 for A non-resident owning Canadian rental property, Calgary, Alberta
We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. The reorganisation used the rollover provisions rather than a taxable transfer, so no tax fell due on the restructuring itself.
The result — A non-resident owning Canadian rental property, Calgary, Alberta
$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 — US LLC Shareholder, 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, Lethbridge, Alberta
A shareholder of a US LLC in Lethbridge, Alberta was selected for review after dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability showed up in the CRA's automated matching. The proposed adjustment on transfer pricing services came to $34,000.
What we did for A shareholder of a US LLC, Lethbridge, Alberta
We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. Every figure in the response traced to a source record the auditor could verify without asking a second question.
The result — A shareholder of a US LLC, Lethbridge, Alberta
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 — US Rental Owner, Kelowna
Client: A Canadian resident with a US rental property · Where: Kelowna, British Columbia · Engagement: 10 weeks, fixed fee
Headcount reached90
Working capital freed$150,000
Missed deadlinesZero
The situation — A Canadian resident with a US rental property, Kelowna, British Columbia
A Canadian resident with a US rental property in Kelowna, British Columbia was growing fast — headcount to 90 in eighteen months — and the back office had not kept up. Foreign accounts that had passed the $100,000 T1135 threshold three years earlier was the first thing to break.
What we did for A Canadian resident with a US rental property, Kelowna, British Columbia
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 — A Canadian resident with a US rental property, Kelowna, British Columbia
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, 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.
