US Expat Tax Return Case Studies

6 worked US Expat 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 us expat tax return work, not a specific client's file.

Case Study 1 · Backlog brought current

$28,000 Of Arbitrary Assessments Vacated After 5 Years — US Branch Operator, Toronto

Client: A Canadian corporation operating a US branch  ·  Where: Toronto, Ontario  ·  Engagement: 9 weeks, fixed fee

Arbitrary tax vacated$28,000
Years brought current5
Account statusCurrent

The situation — A Canadian corporation operating a US branch, Toronto, Ontario

5 years of unfiled returns had turned into notional assessments at a Canadian corporation operating a US branch in Toronto, Ontario. Underneath lay dividends paid to a non-resident shareholder with nothing withheld, leaving the payer holding the liability. Collections had already started.

What we did for A Canadian corporation operating a US branch, Toronto, 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 then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.

The result — A Canadian corporation operating a US branch, Toronto, Ontario

All 5 years were accepted as filed. $28,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 5 years.

Case Study 2 · Deadline rescue

8-Week Turnaround Beat The Deadline And Saved $120,000 — Arizona Snowbird, Ottawa

Client: A snowbird spending winters in Arizona  ·  Where: Ottawa, Ontario  ·  Engagement: 8 weeks, fixed fee

Late-filing penalty avoided$120,000
Filed with15 days to spare
Next yearPapers ready

The situation — A snowbird spending winters in Arizona, Ottawa, Ontario

A snowbird spending winters in Arizona in Ottawa, Ontario was weeks away from the deadline for US expat tax return. Behind that sat foreign accounts that had passed the $100,000 T1135 threshold three years earlier. The exposure if the date slipped was around $120,000.

What we did for A snowbird spending winters in Arizona, Ottawa, Ontario

We filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund. The filing went in complete rather than provisional, so there was no amended return to follow.

The result — A snowbird spending winters in Arizona, Ottawa, Ontario

Filed with 15 days to spare. $120,000 in late-filing penalties avoided, and the working papers are ready for the following year.

Case Study 3 · Planning that cut the bill

Remuneration Review Saved $31,500 Across Corporate And Personal Returns — Cross-Border Contractor, Saskatoon

Client: A contractor working on both sides of the border  ·  Where: Saskatoon, Saskatchewan  ·  Engagement: 9 weeks, fixed fee

Combined saving$31,500
ScopeCorporate + personal
Future yearsNo rework needed

The situation — A contractor working on both sides of the border, Saskatoon, Saskatchewan

Nothing was wrong at a contractor working on both sides of the border in Saskatoon, Saskatchewan. The filings were on time and accurate. What they were not was planned. 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net had never been reviewed.

What we did for A contractor working on both sides of the border, Saskatoon, Saskatchewan

We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. We ran the numbers across both the corporate and personal returns, so the saving was real rather than deferred into someone else's hands.

The result — A contractor working on both sides of the border, Saskatoon, Saskatchewan

$31,500 came off the combined corporate and personal tax bill, and the structure holds for future years without further work.

Case Study 4 · Missed incentive claimed

$60,000 In Credits Claimed That Prior Filings Had Missed — Non-Resident Landlord, Kitchener

Client: A non-resident owning Canadian rental property  ·  Where: Kitchener, Ontario  ·  Engagement: 4 weeks, fixed fee

Credits claimed$60,000
Years adjusted3
Review outcomeNo adjustment

The situation — A non-resident owning Canadian rental property, Kitchener, Ontario

A non-resident owning Canadian rental property in Kitchener, Ontario had been filing for 3 years. In that time, the incentives its activity qualified for were never claimed. Behind that sat US tax paid but no foreign tax credit claimed on the Canadian return.

What we did for A non-resident owning Canadian rental property, Kitchener, Ontario

We tested each activity against the eligibility criteria rather than the description on the invoice. Then we reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.

The result — A non-resident owning Canadian rental property, Kitchener, Ontario

$60,000 in credits claimed, with the open prior years adjusted as well. The claim passed review without adjustment.

Case Study 5 · Structure rebuilt

Reorganisation Completed Tax-Deferred, $16,500 Saved Each Year — Florida Property Owner, Barrie

Client: A family with a Florida vacation property  ·  Where: Barrie, Ontario  ·  Engagement: 5 weeks, fixed fee

Annual saving$16,500
Tax on reorganisationDeferred
Elections filedOn time

The situation — A family with a Florida vacation property, Barrie, Ontario

A family with a Florida vacation property in Barrie, Ontario had outgrown the structure it started with. Winters spent in the United States with the day count kept casually and no residency position documented anywhere was the immediate problem. The longer-term one was that the structure blocked the next step.

What we did for A family with a Florida vacation property, Barrie, Ontario

We mapped the current structure and modelled the target. Then we filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. The tax-deferred elections were filed on time and the supporting valuations documented.

The result — A family with a Florida vacation property, Barrie, Ontario

The reorganisation completed without triggering tax, and the new structure saves approximately $16,500 a year while removing the exposure the old one carried.

Case Study 6 · Records and systems rebuilt

Books Rebuilt From Source, $7,900 In Unclaimed Input Tax Found — US Retirement Account Holder, Calgary

Client: A dual citizen with a US retirement account  ·  Where: Calgary, Alberta  ·  Engagement: 10 weeks, fixed fee

Unclaimed tax found$7,900
Records rebuilt25 months
ProcessDocumented

The situation — A dual citizen with a US retirement account, Calgary, Alberta

A dual citizen with a US retirement account in Calgary, Alberta could not answer basic questions about its own numbers. A US LLC taxed as a corporation in Canada, producing double tax on the same income sat between the bank statements and the ledger.

What we did for A dual citizen with a US retirement account, Calgary, Alberta

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 then documented the process so the work does not depend on any one person remembering how it was done.

The result — A dual citizen with a US retirement account, Calgary, Alberta

Records rebuilt and reconciled, $7,900 recovered in input tax credits that the old file could not support, and a documented monthly process now in place.

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.

Sources. CRA — International and non-resident taxes · Income Tax Act (Justice Laws Website)

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