6 worked Transfer Pricing Study 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 study work, not a specific client's file.
Case Study 1 · Cash and remittance control
$114,000 Of Working Capital Freed From The Tax Cycle — Inbound Assignee, 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, Guelph, Ontario
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 for An inbound transferee on assignment, Guelph, Ontario
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 built a thirteen-week cash view so tax payments stopped competing with payroll for the same dollars.
The result — An inbound transferee on assignment, Guelph, Ontario
$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 — US Branch Operator, Kitchener
Client: A Canadian corporation operating a US branch · Where: Kitchener, Ontario · Engagement: 5 weeks, fixed fee
Recovered$43,000
Open years claimed3
Ongoing trackingIn place
The situation — A Canadian corporation operating a US branch, Kitchener, Ontario
An incentive review at a Canadian corporation operating a US branch 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 for A Canadian corporation operating a US branch, Kitchener, Ontario
We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked, documenting eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result — A Canadian corporation operating a US branch, Kitchener, Ontario
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 — Florida Property Owner, Surrey
Client: A family with a Florida vacation property · Where: Surrey, British Columbia · Engagement: 9 weeks, fixed fee
Tax deferred$660,000
TransferCompleted
RecordsReview-ready
The situation — A family with a Florida vacation property, Surrey, British Columbia
A generational transfer at a family with a Florida vacation property 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 for A family with a Florida vacation property, Surrey, British Columbia
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, sequencing the steps so each one was complete and documented before the next depended on it.
The result — A family with a Florida vacation property, Surrey, British Columbia
$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 — US Rental Owner, Calgary
Client: A Canadian resident with a US rental property · Where: Calgary, Alberta · Engagement: 11 weeks, fixed fee
Penalty avoided$91,000
Turnaround11 weeks
FiledOn time
The situation — A Canadian resident with a US rental property, Calgary, Alberta
A Canadian resident with a US rental property in Calgary, Alberta came to us 11 weeks before its filing deadline with a US LLC taxed as a corporation in Canada, producing double tax on the same income. A late filing would have triggered a penalty of roughly $91,000 before interest.
What we did for A Canadian resident with a US rental property, Calgary, Alberta
We worked backwards from the deadline. We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund, prioritising the items that actually gated the filing and deferring everything that did not.
The result — A Canadian resident with a US rental property, Calgary, Alberta
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 — US-Facing Canadian Corporation, Windsor
Client: A Canadian corporation with US customers · Where: Windsor, Ontario · Engagement: 7 weeks, fixed fee
Cash freed$83,000
Compliance failuresNone
ReportingMonthly
The situation — A Canadian corporation with US customers, Windsor, Ontario
A Canadian corporation with US customers in Windsor, Ontario was opening in a second province — different filing obligations, a different payroll regime, and foreign accounts that had passed the $100,000 T1135 threshold three years earlier already in the file.
What we did for A Canadian corporation with US customers, Windsor, 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 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 — A Canadian corporation with US customers, Windsor, Ontario
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 — Non-Resident Landlord, London
Client: A non-resident owning Canadian rental property · Where: London, Ontario · Engagement: 10 weeks, fixed fee
Adjustment withdrawn$108,000
File closed in10 weeks
Penalties assessedNone
The situation — A non-resident owning Canadian rental property, London, Ontario
A non-resident owning Canadian rental property in London, Ontario received a proposal letter opening a review of transfer pricing study. The CRA had identified winters spent in the United States with the day count kept casually and no residency position documented anywhere and proposed an adjustment of $108,000, with 30 days to respond.
What we did for A non-resident owning Canadian rental property, London, Ontario
We treated the response as an evidence exercise rather than an argument. We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns, then indexed every supporting document against the specific line the auditor had questioned.
The result — A non-resident owning Canadian rental property, London, Ontario
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, 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.
