6 Transfer Pricing Study 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 study work, not a general example.
Case Study 1 · Cash and remittance control
$114,000 Of Working Capital Freed From The Tax Cycle — Inbound Transferee on Assignment, Guelph
Client: An inbound transferee on assignment · Where: Guelph, Ontario · Engagement: 3 weeks, fixed fee
Working capital freed$114,000
On-time remittancesEvery period since
Forecast horizon13 weeks
The situation
An inbound transferee on assignment in Guelph, Ontario was profitable on paper and short of cash every month. US tax paid but no foreign tax credit claimed on the Canadian return explained most of the gap.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely and built a thirteen-week cash view so tax payments stopped competing with payroll for the same dollars.
The result
$114,000 was released back into working capital. Remittances have been on time every period since, and the forecast shows the tax outflow before it lands.
Case Study 2 · Missed incentive claimed
Incentive Review Recovered $43,000 Across 3 Open Years — Snowbird Spending Winters in, Kitchener
Client: A snowbird spending winters in Arizona · Where: Kitchener, Ontario · Engagement: 5 weeks, fixed fee
Recovered$43,000
Open years claimed3
Ongoing trackingIn place
The situation
An incentive review at a snowbird spending winters in Arizona in Kitchener, Ontario started from a simple question: what has never been claimed? The answer ran to 3 years, driven by 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, documenting eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result
The credits produced $43,000 across the open years, and the tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.
Case Study 3 · Sale and succession
Intergenerational Transfer Completed With $660,000 Deferred — Shareholder of a US, Surrey
Client: A shareholder of a US LLC · Where: Surrey, British Columbia · Engagement: 9 weeks, fixed fee
Tax deferred$660,000
TransferCompleted
RecordsReview-ready
The situation
A generational transfer at a shareholder of a US LLC in Surrey, British Columbia had been discussed for years without a plan. A shareholder loan balance that would have been picked up as income on closing meant the transfer as contemplated would have been fully taxable.
What we did
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward, sequencing the steps so each one was complete and documented before the next depended on it.
The result
$660,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
Case Study 4 · Deadline rescue
Filed On Time From A Standing Start, $91,000 Penalty Avoided — Non-Resident Owning Canadian Rental, Calgary
Client: A non-resident owning Canadian rental property · Where: Calgary, Alberta · Engagement: 11 weeks, fixed fee
Penalty avoided$91,000
Turnaround11 weeks
FiledOn time
The situation
A non-resident owning Canadian rental property in Calgary, Alberta came to us 11 weeks before its filing deadline with 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. A late filing would have triggered a penalty of roughly $91,000 before interest.
What we did
We worked backwards from the deadline. We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused, prioritising the items that actually gated the filing and deferring everything that did not.
The result
The return was filed on time and complete. The $91,000 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.
Case Study 5 · Scaling without breaking
Growth Handled Without A Missed Filing, $83,000 Freed — Canadian Resident with a, Windsor
Client: A Canadian resident with a US rental property · Where: Windsor, Ontario · Engagement: 7 weeks, fixed fee
Cash freed$83,000
Compliance failuresNone
ReportingMonthly
The situation
A Canadian resident with a US rental property in Windsor, Ontario was opening in a second province — different filing obligations, a different payroll regime, and a departure year filed as a normal resident return with no deemed disposition reported already in the file.
What we did
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely 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. $83,000 of cash was released, and the monthly reporting now flags a problem while it is still small.
Case Study 6 · CRA review defended
$108,000 Proposed Adjustment Withdrawn In Full — Dual Citizen with a, London
Client: A dual citizen with a US retirement account · Where: London, Ontario · Engagement: 10 weeks, fixed fee
Adjustment withdrawn$108,000
File closed in10 weeks
Penalties assessedNone
The situation
A dual citizen with a US retirement account in London, Ontario received a proposal letter opening a review of transfer pricing study. The CRA had identified US tax paid but no foreign tax credit claimed on the Canadian return and proposed an adjustment of $108,000, with 30 days to respond.
What we did
We treated the response as an evidence exercise rather than an argument. We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, then indexed every supporting document against the specific line the auditor had questioned.
The result
The proposed adjustment was withdrawn in full — all $108,000 of it. The file closed in 10 weeks with no change to the assessed amounts and no penalty.
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.
