6 worked Treaty-Based Corporate Tax Return 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 treaty-based corporate tax return work, not a specific client's file.
Case Study 1 · Planning that cut the bill
$45,000 Cut From The Annual Tax Bill — Inbound Assignee, Vancouver
Client: An inbound transferee on assignment · Where: Vancouver, British Columbia · Engagement: 11 weeks, fixed fee
First-year saving$45,000
RepeatsAnnually
Filing positionUnchanged in risk
The situation — An inbound transferee on assignment, Vancouver, British Columbia
An inbound transferee on assignment in Vancouver, British Columbia was compliant but paying more than it needed to. The prior year had been filed correctly. It still left foreign accounts that had passed the $100,000 T1135 threshold three years earlier on the table.
What we did for An inbound transferee on assignment, Vancouver, British Columbia
We modelled the current position against the alternatives before changing anything. Then we filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely.
The result — An inbound transferee on assignment, Vancouver, British Columbia
The change saved $45,000 in the first year and repeats annually. Nothing about the filings became more aggressive. The position is simply the one the rules already allowed.
Case Study 2 · Structure rebuilt
Corporate Structure Rebuilt For $38,500 Of Annual Savings — Arizona Snowbird, Windsor
Client: A snowbird spending winters in Arizona · Where: Windsor, Ontario · Engagement: 11 weeks, fixed fee
Saving per year$38,500
DocumentationComplete
Transfer basisRollover
The situation — A snowbird spending winters in Arizona, Windsor, Ontario
The structure at a snowbird spending winters in Arizona in Windsor, Ontario dated from years earlier. It had been set up for a business that no longer existed. Winters spent in the United States with the day count kept casually and no residency position documented anywhere had become expensive.
What we did for A snowbird spending winters in Arizona, Windsor, Ontario
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 snowbird spending winters in Arizona, Windsor, Ontario
$38,500 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
Case Study 3 · Scaling without breaking
Scaled To 88 Staff With $72,000 Of Working Capital Freed — Florida Property Owner, Saskatoon
Client: A family with a Florida vacation property · Where: Saskatoon, Saskatchewan · Engagement: 8 weeks, fixed fee
Headcount reached88
Working capital freed$72,000
Missed deadlinesZero
The situation — A family with a Florida vacation property, Saskatoon, Saskatchewan
A family with a Florida vacation property in Saskatoon, Saskatchewan was growing fast, with headcount reaching 88 in eighteen months. The back office had not kept up. Dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability was the first thing to break.
What we did for A family with a Florida vacation property, Saskatoon, Saskatchewan
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. We built the compliance calendar for the size the business was becoming rather than the size it had been.
The result — A family with a Florida vacation property, Saskatoon, Saskatchewan
The business reached 88 staff with no missed remittance and no late filing. $72,000 of working capital was freed in the process.
Case Study 4 · Sale and succession
Intergenerational Transfer Completed With $630,000 Deferred — Canadian on US Payroll, Mississauga
Client: A Canadian with a US employer · Where: Mississauga, Ontario · Engagement: 6 weeks, fixed fee
Tax deferred$630,000
TransferCompleted
RecordsReview-ready
The situation — A Canadian with a US employer, Mississauga, Ontario
A generational transfer at a Canadian with a US employer in Mississauga, Ontario 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 Canadian with a US employer, Mississauga, Ontario
We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. We sequenced the steps so each one was complete and documented before the next depended on it.
The result — A Canadian with a US employer, Mississauga, Ontario
$630,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
Case Study 5 · Cash and remittance control
$96,000 Of Working Capital Freed From The Tax Cycle — US-Facing Canadian Corporation, Moncton
Client: A Canadian corporation with US customers · Where: Moncton, New Brunswick · Engagement: 9 weeks, fixed fee
Working capital freed$96,000
On-time remittancesEvery period since
Forecast horizon13 weeks
The situation — A Canadian corporation with US customers, Moncton, New Brunswick
A Canadian corporation with US customers in Moncton, New Brunswick 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 A Canadian corporation with US customers, Moncton, New Brunswick
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We also built a thirteen-week cash view so tax payments stopped competing with payroll for the same dollars.
The result — A Canadian corporation with US customers, Moncton, New Brunswick
$96,000 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 6 · Backlog brought current
Collections Halted And $24,000 Cut From A 3-Year Backlog — Cross-Border Contractor, London
Client: A contractor working on both sides of the border · Where: London, Ontario · Engagement: 7 weeks, fixed fee
Balance reduced by$24,000
Backlog cleared3 years
CollectionsHalted
The situation — A contractor working on both sides of the border, London, Ontario
By the time a contractor working on both sides of the border in London, Ontario called, 3 years were outstanding. The CRA had assessed on estimates. Underneath it sat a departure year filed as a normal resident return with no deemed disposition reported.
What we did for A contractor working on both sides of the border, London, Ontario
We reconstructed the records year by year. We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. Each filing replaced an arbitrary assessment with a real one.
The result — A contractor working on both sides of the border, London, Ontario
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $24,000, and a relief application addressed part of the accumulated interest.
Reviewed by Udit Gupta, Founder and Tax Accountant for the 2025 tax year. 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.
