6 worked US Form 1065 Partnership 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 form 1065 partnership filing work, not a specific client's file.
Case Study 1 · CRA review defended
$55,000 Reassessment Reduced To Nil On Review — US Citizen in Canada, Lethbridge
Client: A US citizen living in Canada · Where: Lethbridge, Alberta · Engagement: 6 weeks, fixed fee
Reassessment reduced toNil
Tax protected$55,000
Prior filingsUndisturbed
The situation — A US citizen living in Canada, Lethbridge, Alberta
A review notice arrived at a US citizen living in Canada in Lethbridge, Alberta, covering US form 1065 partnership filing for two tax years. The auditor's working position was an adjustment of $55,000. It was driven by invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken.
What we did for A US citizen living in Canada, Lethbridge, Alberta
Rather than negotiate, we rebuilt the record. 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. We then submitted a point-by-point response that answered each proposed adjustment with the document behind it.
The result — A US citizen living in Canada, Lethbridge, Alberta
The auditor accepted the documented position and closed the review without adjustment, protecting $55,000 and leaving the prior filings undisturbed.
Case Study 2 · Backlog brought current
Collections Halted And $109,000 Cut From A 7-Year Backlog — Florida Property Owner, Red Deer
Client: A family with a Florida vacation property · Where: Red Deer, Alberta · Engagement: 3 weeks, fixed fee
Balance reduced by$109,000
Backlog cleared7 years
CollectionsHalted
The situation — A family with a Florida vacation property, Red Deer, Alberta
By the time a family with a Florida vacation property in Red Deer, Alberta called, 7 years were outstanding. The CRA had assessed on estimates. Underneath it sat US tax paid but no foreign tax credit claimed on the Canadian return.
What we did for A family with a Florida vacation property, Red Deer, Alberta
We reconstructed the records year by year. We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. Each filing replaced an arbitrary assessment with a real one.
The result — A family with a Florida vacation property, Red Deer, Alberta
The account is current. Filing on real numbers rather than CRA estimates reduced the balance by $109,000, and a relief application addressed part of the accumulated interest.
Case Study 3 · Deadline rescue
Filed On Time From A Standing Start, $43,000 Penalty Avoided — US LLC Shareholder, Halifax
Client: A shareholder of a US LLC · Where: Halifax, Nova Scotia · Engagement: 5 weeks, fixed fee
Penalty avoided$43,000
Turnaround5 weeks
FiledOn time
The situation — A shareholder of a US LLC, Halifax, Nova Scotia
A shareholder of a US LLC in Halifax, Nova Scotia came to us 5 weeks before its filing deadline. The file came with a departure year filed as a normal resident return with no deemed disposition reported. A late filing would have triggered a penalty of roughly $43,000 before interest.
What we did for A shareholder of a US LLC, Halifax, Nova Scotia
We worked backwards from the deadline. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We prioritised the items that actually gated the filing and deferred everything that did not.
The result — A shareholder of a US LLC, Halifax, Nova Scotia
The return was filed on time and complete. The $43,000 penalty never arose, and the compliance calendar we set means the next deadline is scheduled rather than discovered.
Case Study 4 · Planning that cut the bill
$74,000 Saved By Correcting What Prior Filings Had Missed — Mid-Year Emigrant, Vancouver
Client: An emigrant who left Canada mid-year · Where: Vancouver, British Columbia · Engagement: 3 weeks, fixed fee
Saving identified$74,000
RecurringYes
Positions documentedAll
The situation — An emigrant who left Canada mid-year, Vancouver, British Columbia
An emigrant who left Canada mid-year in Vancouver, British Columbia asked for a second opinion on US form 1065 partnership filing. That followed three years of rising tax. The review found 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
What we did for An emigrant who left Canada mid-year, Vancouver, British Columbia
We built the comparison first: current structure against two alternatives. Then we reported the deemed disposition properly on the departure return and claimed the foreign tax credits that had been left unused.
The result — An emigrant who left Canada mid-year, Vancouver, British Columbia
First-year saving of $74,000, with the same benefit recurring. Every position taken is documented and supported in the file.
Case Study 5 · Missed incentive claimed
Incentive Review Recovered $138,000 Across 7 Open Years — Arizona Snowbird, Moncton
Client: A snowbird spending winters in Arizona · Where: Moncton, New Brunswick · Engagement: 3 weeks, fixed fee
Recovered$138,000
Open years claimed7
Ongoing trackingIn place
The situation — A snowbird spending winters in Arizona, Moncton, New Brunswick
An incentive review at a snowbird spending winters in Arizona in Moncton, New Brunswick started from a simple question: what has never been claimed? The answer ran to 7 years. It was driven by a departure year filed as a normal resident return with no deemed disposition reported.
What we did for A snowbird spending winters in Arizona, Moncton, New Brunswick
We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. We documented eligibility to the standard a reviewer would apply rather than the standard a claim form requires.
The result — A snowbird spending winters in Arizona, Moncton, New Brunswick
The credits produced $138,000 across the open years. The tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.
Case Study 6 · Structure rebuilt
Reorganisation Completed Tax-Deferred, $66,000 Saved Each Year — US Rental Owner, Burnaby
Client: A Canadian resident with a US rental property · Where: Burnaby, British Columbia · Engagement: 7 weeks, fixed fee
Annual saving$66,000
Tax on reorganisationDeferred
Elections filedOn time
The situation — A Canadian resident with a US rental property, Burnaby, British Columbia
A Canadian resident with a US rental property in Burnaby, British Columbia had outgrown the structure it started with. Foreign accounts that had passed the $100,000 T1135 threshold three years earlier was the immediate problem. The longer-term one was that the structure blocked the next step.
What we did for A Canadian resident with a US rental property, Burnaby, British Columbia
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 Canadian resident with a US rental property, Burnaby, British Columbia
The reorganisation completed without triggering tax, and the new structure saves approximately $66,000 a year while removing the exposure the old one carried.
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.
