6 worked US Business Tax Filing 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 us business tax filing work, not a specific client's file.
Case Study 1 · Missed incentive claimed
$143,000 In Credits Claimed That Prior Filings Had Missed — US Citizen in Canada, Kitchener
Client: A US citizen living in Canada · Where: Kitchener, Ontario · Engagement: 5 weeks, fixed fee
Credits claimed$143,000
Years adjusted4
Review outcomeNo adjustment
The situation — A US citizen living in Canada, Kitchener, Ontario
A US citizen living in Canada in Kitchener, Ontario had been filing for 4 years. In that time, the incentives its activity qualified for were never claimed. Behind that sat a US LLC taxed as a corporation in Canada, producing double tax on the same income.
What we did for A US citizen living in Canada, Kitchener, Ontario
We tested each activity against the eligibility criteria rather than the description on the invoice. Then 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.
The result — A US citizen living in Canada, Kitchener, Ontario
$143,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.
Case Study 2 · Sale and succession
$305,000 Sheltered By The Lifetime Capital Gains Exemption — US Retirement Account Holder, Victoria
Client: A dual citizen with a US retirement account · Where: Victoria, British Columbia · Engagement: 5 weeks, fixed fee
Gain sheltered$305,000
ClosingOn schedule
Share qualificationMet
The situation — A dual citizen with a US retirement account, Victoria, British Columbia
A dual citizen with a US retirement account in Victoria, British Columbia had an offer on the table and 26 months to close. The shares did not qualify for the capital gains exemption. Retained cash well above what the business needed to operate was part of the reason.
What we did for A dual citizen with a US retirement account, Victoria, British Columbia
We purified the corporation so the shares met the qualifying tests. We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. All of it was done well ahead of the closing date.
The result — A dual citizen with a US retirement account, Victoria, British Columbia
The sale closed on schedule with $305,000 sheltered by the lifetime capital gains exemption across the shareholders.
Case Study 3 · Deadline rescue
6-Week Turnaround Beat The Deadline And Saved $51,000 — US LLC Shareholder, Moncton
Client: A shareholder of a US LLC · Where: Moncton, New Brunswick · Engagement: 6 weeks, fixed fee
Late-filing penalty avoided$51,000
Filed with16 days to spare
Next yearPapers ready
The situation — A shareholder of a US LLC, Moncton, New Brunswick
A shareholder of a US LLC in Moncton, New Brunswick was weeks away from the deadline for US business tax filing. Behind that sat a departure year filed as a normal resident return with no deemed disposition reported. The exposure if the date slipped was around $51,000.
What we did for A shareholder of a US LLC, Moncton, New Brunswick
We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. The filing went in complete rather than provisional, so there was no amended return to follow.
The result — A shareholder of a US LLC, Moncton, New Brunswick
Filed with 16 days to spare. $51,000 in late-filing penalties avoided, and the working papers are ready for the following year.
Case Study 4 · Scaling without breaking
Second-Province Expansion Handled, $134,000 Of Cash Released — US Pension Recipient, Kelowna
Client: A Canadian resident receiving US pension income · Where: Kelowna, British Columbia · Engagement: 8 weeks, fixed fee
Cash released$134,000
New registrationsComplete on day one
Compliance gapsNone
The situation — A Canadian resident receiving US pension income, Kelowna, British Columbia
Revenue at a Canadian resident receiving US pension income in Kelowna, British Columbia was up sharply and cash was tighter than ever. Underneath it sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
What we did for A Canadian resident receiving US pension income, Kelowna, British Columbia
We reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused. Every new obligation was set up before it was triggered, not after. That covered registration, remittance frequency and provincial filing.
The result — A Canadian resident receiving US pension income, Kelowna, British Columbia
$134,000 of cash was released from the working capital cycle. The expansion completed with every registration and filing obligation covered from day one.
Case Study 5 · CRA review defended
$129,000 Proposed Adjustment Withdrawn In Full — Arizona Snowbird, Lethbridge
Client: A snowbird spending winters in Arizona · Where: Lethbridge, Alberta · Engagement: 5 weeks, fixed fee
Adjustment withdrawn$129,000
File closed in5 weeks
Penalties assessedNone
The situation — A snowbird spending winters in Arizona, Lethbridge, Alberta
A snowbird spending winters in Arizona in Lethbridge, Alberta received a proposal letter opening a review of US business tax filing. The CRA had identified a US LLC taxed as a corporation in Canada, producing double tax on the same income. It proposed an adjustment of $129,000, with 30 days to respond.
What we did for A snowbird spending winters in Arizona, Lethbridge, Alberta
We treated the response as an evidence exercise rather than an argument. We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. We then indexed every supporting document against the specific line the auditor had questioned.
The result — A snowbird spending winters in Arizona, Lethbridge, Alberta
The proposed adjustment was withdrawn in full — all $129,000 of it. The file closed in 5 weeks with no change to the assessed amounts and no penalty.
Case Study 6 · Structure rebuilt
Corporate Structure Rebuilt For $56,000 Of Annual Savings — Canadian on US Payroll, Calgary
Client: A Canadian with a US employer · Where: Calgary, Alberta · Engagement: 3 weeks, fixed fee
Saving per year$56,000
DocumentationComplete
Transfer basisRollover
The situation — A Canadian with a US employer, Calgary, Alberta
The structure at a Canadian with a US employer in Calgary, Alberta dated from years earlier. It had been set up for a business that no longer existed. Foreign accounts that had passed the $100,000 T1135 threshold three years earlier had become expensive.
What we did for A Canadian with a US employer, Calgary, Alberta
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 — A Canadian with a US employer, Calgary, Alberta
$56,000 of annual saving, achieved on a tax-deferred basis. The minute book, elections and valuations are all in the file.
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.
