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At Tax Filings Canada, we handle every part of your intercompany transaction review, from the filing itself to the planning around it. Our accountants work with businesses and individuals every week, so the filing is right whether you file personally or through a corporation.
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Intercompany Transaction Review from Tax Filings Canada gives Canadians with US ties and non-residents earning Canadian income treaty positions, foreign tax credits, T1135 disclosure and non-resident withholding at a cheap fixed fee agreed before work begins — no hourly billing, no surprise invoices.
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We prepare your intercompany transaction review and every supporting schedule.
You review each figure and approve before anything is filed.
We file with the CRA, and you pay only after it is complete.
| Factor | Tax Filings Canada | Typical Firm |
|---|---|---|
| Pricing model | Fixed, flat fee | Hourly / unpredictable |
| Payment | Pay after service | Upfront retainer |
| Price match | Yes, on written quotes | Rarely |
| CRA audit support | Included | Billed extra |
| Typical turnaround | 3-5 business days | 2-4 weeks |
CRA reviews are won on documentation: every figure filed should trace to a source document, and deadlines — 90 days for an objection — are unforgiving. Section 216 and 217 elections can substantially reduce non-resident withholding on Canadian rents and pensions when filed on time. Because the fee is fixed and cheap, the economics stay predictable whether your file is simple or messy.
What follows is the working view of a tax practitioner who prepares intercompany transaction review week in, week out — the points that decide real files.
Here is where every serious conversation about Intercompany Transaction Review begins: The Canada–US treaty allocates taxing rights, but relief is not automatic. A foreign tax credit or treaty position has to be claimed on a filed return.
A related rule tends to get overlooked precisely because the first one draws all the attention: Non-residents earning Canadian rental income face 25% withholding on gross rent unless a section 216 election is filed. The election taxes the net instead. A file is only as strong as what backs it up, which brings us to the next rule: A US LLC is a flow-through for US purposes but a corporation for Canadian purposes. That mismatch routinely produces double taxation unless the structure is corrected.
So where does that leave you? In most cases, with a decision about whether to work through intercompany transaction review alone or hand the moving parts to a tax expert who tracks them for a living. The smoothest files are the ones where the client arrives with these records already assembled.
Our terms are the same for every engagement: a fixed fee agreed before work begins, a full review with you before filing, and payment only after the service is complete.
Providing transparent fixed pricing and high-quality compliance work for your intercompany transaction review requirements.
Coverage: Standard bookkeeping and intercompany transaction review preparation.
Ideal for early-stage startups and sole proprietors.
Book NowCoverage: Full-service bookkeeping, filings, and CRA compliance support.
Perfect for established small businesses.
Book NowCoverage: Strategic advisory and fractional CFO integration.
Ideal for companies seeking high-growth financial structuring.
Book NowWhy you should partner with Tax Filings Canada Experts for all your intercompany transaction review needs?
Providing tailored intercompany transaction review services to ensure compliance and maximize deductions.
Our tax accountants keep your business compliant with federal and provincial tax rules.
A dedicated team that handles your financials quickly, accurately, and without upfront fees.
Dedicated preparation processes customized for Canadian businesses.
Advanced accounting software integrations with QuickBooks, Xero, and wave accounting.
Customized packages designed to grow as your business operations expand.
Our clear four-step workflow ensuring absolute tax optimization and complete CRA compliance.
Start with a free, no-obligation consultation to review your business’s financial, tax filing and compliance needs and outline our affordable solutions.
Receive a comprehensive checklist and securely provide the required financial records and documents.
Our tax accountant and accounting experts carefully prepare your filings, identify all applicable deductions and credits, and conduct thorough reviews.
We file your documents electronically with the Canada Revenue Agency (CRA) on time and provide post-filing support.
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See how our expert Intercompany Transaction Review tax and accounting services have helped Canadian businesses save money and stay compliant.
A $105,000 reassessment was proposed against a Canadian resident receiving US pension income in London, Ontario. It followed a US LLC taxed as a corporation in Canada, producing double tax on the same income. The documented response reduced it to nil.
A review notice arrived at a Canadian resident receiving US pension income in London, Ontario, covering intercompany transaction review for two tax years. The auditor's working position was an adjustment of $105,000. It was driven by a US LLC taxed as a corporation in Canada, producing double tax on the same income. Rather than negotiate, we rebuilt the record. We restructured the US holding so the Canadian and US characterisations aligned, ending the double taxation going forward. We then submitted a point-by-point response that answered each proposed adjustment with the document behind it. The auditor accepted the documented position and closed the review without adjustment, protecting $105,000 and leaving the prior filings undisturbed.
A family transfer at an emigrant who left Canada mid-year in Windsor, Ontario would have been fully taxable. The reason was a shareholder loan balance that would have been picked up as income on closing. Restructuring deferred $580,000.
A generational transfer at an emigrant who left Canada mid-year in Windsor, 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. We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely. We sequenced the steps so each one was complete and documented before the next depended on it. $580,000 of tax was deferred through the transfer, and the successor generation took over a corporation whose records stood up to review.
Closing the books at a Canadian resident with a US rental property in Calgary, Alberta took 12 weeks. The cause was a departure year filed as a normal resident return with no deemed disposition reported. It now takes 5 days.
The accounting file at a Canadian resident with a US rental property in Calgary, Alberta had a weak foundation. It was built on a departure year filed as a normal resident return with no deemed disposition reported. The year-end had taken 12 weeks each of the last three years. We aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns. We also moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild. The file reconciles. Month-end closes in 5 days instead of 12 weeks, and the year-end is a review rather than a reconstruction.
A Canadian with a US employer in Surrey, British Columbia was filing correctly and still overpaying. The reason was foreign accounts that had passed the $100,000 T1135 threshold three years earlier. Restructuring the position cut $28,000 from the annual bill.
A Canadian with a US employer in Surrey, 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. We modelled the current position against the alternatives before changing anything. Then we reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked. The change saved $28,000 in the first year and repeats annually. Nothing about the filings became more aggressive. The position is simply the one the rules already allowed.
5 years of returns were outstanding at a US citizen living in Canada in Kitchener, Ontario. That came on top of invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken. Filing on real numbers removed $137,000 of assessed tax.
A US citizen living in Canada in Kitchener, Ontario had not filed for 5 years. The CRA had issued arbitrary assessments. The business was carrying invoices paid to a non-resident consultant working on site in Canada with no Regulation 105 withholding taken. That came on top of a growing interest balance. We started with the oldest year and worked forward so each year's closing balances fed the next. 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 filed the years in sequence rather than all at once. Every year is now filed and assessed on actual figures. The notional assessments were vacated and $137,000 of the estimated balance came off, with a payment arrangement covering the rest.
An inbound transferee on assignment in Guelph, Ontario was carrying $68,000 of penalties and interest. The charges arose from 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. A relief application cancelled that amount.
An assessment of $68,000 landed at an inbound transferee on assignment in Guelph, Ontario following a desk review. It turned on 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net. The auditor had not seen the records behind it. 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 set out the legislative basis for the position alongside the documents supporting it. $68,000 of penalties and interest was cancelled under the taxpayer relief provisions, and the underlying assessment was adjusted to match the filed position.
Meet the specialists behind your Intercompany Transaction Review filings. Our Partners Are Alumni of the World's Top Accounting and Tax Institutions
CA (ICAI), CA (MIA), CPA Canada (In-Depth Tax Program)
Canada Tax, International Tax, Cross Border Tax, Transfer Pricing
International Tax, Transfer Pricing Specialist
CA (ICAI), Canada Tax Expert
CA. Fractional CFO and Senior Advisory Specialist
Same fixed fees in every province. Find your city or your sector.
Direct answers to what Canadian business owners actually ask before hiring an accountant.
Intercompany Transaction Review starts at a fixed fee quoted before any work begins. The quote is locked at the outset and does not change mid-engagement, and you pay only after you have reviewed and approved the deliverable. Compare every plan on our transparent pricing page.
At minimum: prior-year returns and notices of assessment, your bank and credit-card statements for the fiscal period, payroll records if you have employees, and GST/HST filings. We send a checklist tailored to your situation after the free 15-minute call.
Most engagements are completed within 3 to 5 business days once your documents are complete. Catch-up work covering multiple years takes longer, and we tell you the realistic timeline before you commit rather than after.
We respond on your behalf at no extra charge for any return we prepared. Every figure we file is supported by documentation retained in your file, which is what turns a CRA review from a crisis into correspondence. See how our CRA audit representation works.
Yes. Late filing penalties compound at 5% of the balance owing plus 1% per month, so the cost of waiting is real. We prioritise catch-up work and, where eligible, file under the CRA's Voluntary Disclosures Program to reduce penalties.
Yes. We serve clients in every province and territory at the same fixed fees, so your location does not change the price or the service. Browse our coverage across Canada to find your city.
We work across construction, healthcare, e-commerce, professional services, restaurants, real estate, transportation, technology and non-profits, each with its own deduction profile and CRA scrutiny patterns. See all industries we serve.
Software applies the rules you already know about. An experienced tax accountant finds the ones you do not: capital cost allowance timing, the small business deduction threshold, shareholder loan repayment rules, and TOSI exposure on family dividends. The fee is usually smaller than the deductions it surfaces.
Our intercompany transaction review services include complete filing, compliance management, and strategic advice customized to Canadian tax laws.
You can start by booking a free 15-minute call. We will review your files, provide a fixed quote, and start working immediately.
The honest answer comes down to one rule. Departure from Canada triggers a deemed disposition of most property at fair market value. The resulting gain has to be reported on the final resident return. That is the part we verify before anything is filed.
Our answer starts where the legislation starts. A payment to a non-resident for services performed in Canada is subject to 15 percent withholding under Regulation 105. That applies whether or not the non-resident ends up owing Canadian tax. A waiver has to be applied for before the payment is made, and the payer that withheld nothing is the one assessed. From there it is a matter of applying it to your year — and that application, not the rule itself, is where a tax consultant earns the fee.
The questions Canadians actually search on this topic, answered plainly. Browse every question in the Canadian tax answers directory.
HST combines the 5% federal GST with a provincial component in five participating provinces. For 2026 the combined rates are 13% in Ontario, 15% in New Brunswick, Newfoundland and Labrador, and Prince Edward Island, and 14% in Nova Scotia since 1 April 2025. Elsewhere you charge the 5% GST alone, or GST plus a separate provincial tax. The rate follows the province of supply, not where your business sits.
File a T1 return for the year, sending it electronically with CRA-certified software or mailing a paper return. Gather your slips and receipts first and check them against the ones listed in My Account. For the 2025 tax year the filing and payment deadline was 30 April 2026, or 15 June 2026 to file if you or your spouse were self-employed, with payment still due 30 April 2026. CRA online filing for 2025 returns closes 29 January 2027.
Scholarships, fellowships and bursaries are reported on a T4A, yet most students pay no tax on them. A full-time student in a qualifying programme who is eligible to claim the education amount is generally exempt on amounts received for that programme. Part-time students get a limited exemption tied to tuition and required materials. Amounts paid for services performed, such as a paid assistantship, or received as a research grant are treated differently and can be taxable.
No. Revenue is income you have earned and belongs on the income statement, not among liabilities. Money taken before you deliver the goods or service is different: unearned or deferred revenue is a liability until you perform the work. Sales tax you collect is also a liability rather than revenue. Booking customer deposits straight to sales is a common error that overstates profit and distorts the figures on your GST/HST return.
Often yes. A non-resident business making taxable supplies in Canada must register and charge GST/HST once it passes $30,000 of taxable revenue over four consecutive calendar quarters or within a single quarter, using the rate for the customer's province: 5% GST, 13% in Ontario, 14% in Nova Scotia from 1 April 2025. Simplified registration rules apply to digital products and platform sales to Canadian consumers. A US supplier also pays GST/HST on its own Canadian purchases.
No. QST is a separate Quebec tax administered by Revenu Quebec, and it cannot be recovered on your federal GST/HST return. Only a business registered for QST can claim input tax refunds for the 9.975% QST it pays, and registration normally follows from making taxable supplies in Quebec. An Ontario business with no QST registration treats the QST on a Quebec invoice as part of the cost of the expense. Check Revenu Quebec for the registration rules.
For 2026 an employer matches CPP at 5.95% on earnings between $3,500 and $74,600, up to $4,230.45 per employee, plus CPP2 at 4% on earnings between $74,600 and $85,000, up to $416. Employment Insurance costs 1.4 times the employee premium, which is 2.282% of insurable earnings up to $68,900, a maximum of $1,572.30. Provincial payroll or workers' compensation levies sit on top of that.
Yes. Internet access is a taxable supply, so your bill carries GST at 5% for 2026, or your province's HST rate instead, and provincial sales tax where that province taxes telecommunications. Bundles of internet, television and phone are treated the same way. If you are registered and use the connection in your business, claim the tax on the business share as an input tax credit rather than expensing the whole amount.
Check CRA My Account or the CRA's mobile service: once the return is assessed, it shows the refund amount and the payment date. An electronically filed return is usually processed in about two weeks, while a non-resident return can take up to 16 weeks. Set up direct deposit so the money goes straight to your bank rather than waiting on a cheque. Amounts you owe the CRA or other government programs can reduce it.
Reportable income is every amount you have to show on your return, which is wider than the amount you finally pay tax on. It takes in employment income, self-employment and side income, tips, interest, dividends, capital gains, rent, pensions and most benefits, slip or no slip. Foreign income is reportable too, even where tax was already paid abroad. Report everything first, then claim the deductions and credits that reduce what is taxable and what you owe.
Pension income splitting is the largest lever for most couples: up to 50% of eligible pension income can be reported by a lower-income spouse, and RRIF income qualifies from age 65. Beyond that, sequence withdrawals from registered and non-registered accounts to keep net income under the Old Age Security recovery threshold, use TFSA withdrawals that count as no income at all, claim the pension and age credits, and consider drawing down RRSPs before the plan must be wound up, which is by the end of the calendar year in which you turn 71 and not on your 71st birthday.
Yes. If you are resident in Canada, a withdrawal from a US 401(k) is fully taxable here as pension income in the year you receive it, converted to Canadian dollars. The US plan administrator normally withholds American tax at source, and you claim that withholding as a foreign tax credit so the same money is not taxed twice. A transfer to an RRSP is possible in limited circumstances. Get advice before withdrawing, because timing changes the outcome.
Reviewed and fact-checked by Udit Gupta
Ex Big 4 — Ernst & Young, Deloitte · International & cross-border tax specialist · CPA Canada (In-Depth Tax Program) · Chartered accountant, ICAI & MIA
Udit Gupta has over 15 years of experience helping corporations and business owners with corporate structuring, corporate tax filing, bookkeeping, payroll, GST/HST, cross-border tax and CRA representation. He is Big 4 trained, at Ernst & Young and Deloitte, and qualified as a chartered accountant in India and again in Malaysia. In 2014 he founded his accounting practice to serve entrepreneurs, startups and non-resident business owners across Canada. View full member bio.
The Institute of Chartered Accountants of India — member 521458 · Malaysian Institute of Accountants — member CA 44667 · Ex Big 4: Ernst & Young, Deloitte · CPA Canada (In-Depth Tax Program), completed 19 Dec 2023 · In-Depth GST/HST Part I, 12 Jul 2022 · Part II, 5 Jul 2023
Editorial policy. Every page is researched against primary sources — the Income Tax Act, CRA publications and CPA Canada guidance — and every rate or threshold is stated with the tax year it applies to.
Sources. CRA — Businesses · Income Tax Act (Justice Laws Website)
