Tax Accountant for Canadian Companies Expanding to the US in Ontario and Across Canada
The decision that costs the most is the one you make before the first American dollar arrives: what you form, and where. CRA generally treats a US LLC as a corporation while the United States treats it as fiscally transparent, so the two systems can end up disagreeing about who earned the income and who paid the tax — and that disagreement is how a foreign tax credit under ITA section 126 quietly gets lost. We model the structure before it is formed rather than unwinding it two years later. From there the work is specific. Whether the United States can tax your business profits at all is a treaty question under Article V and Article VII. Every intercompany charge becomes a transfer pricing question under ITA section 247 with a T106 behind it. The new subsidiary brings an annual Form T1134 and the sections 91 and 95 attribution rules with it. Value coming home engages Part XIII withholding. We advise on the Canadian side and say so plainly — with AFFORDABLE flat fees.
AFFORDABLE US Expansion Tax Accountant
Expanding into the United States is not a filing problem. It is a structuring problem that turns into a filing problem about eighteen months later, and by then the structure is already built. The single most expensive thing we see is a Canadian company that formed a US LLC because it was quick and cheap, without anyone modelling what the two tax systems would each say about it. CRA generally treats that LLC as a corporation. The United States generally treats it as fiscally transparent, meaning the income is taxed in the hands of its members rather than the entity. When the two countries disagree about who earned the income and who paid the tax on it, relief under ITA section 126 becomes difficult to claim, and tax that should have been credited is simply paid twice. At Gondaliya CPA, we model the entity decision, the treaty position and the intercompany pricing before the expansion happens, providing AFFORDABLE flat-fee support that keeps you CRA-compliant and stops you paying more tax than you owe.
As a cross-border accountant for Canadian companies expanding to the US, we work with technology companies opening a first American office, manufacturers and distributors selling into the United States, professional services and engineering firms taking on American engagements, and ecommerce businesses holding inventory across the border. The work is year-round rather than annual, because the obligations that follow a US subsidiary are annual: Form T1134 on the affiliate, Form T106 on the non-arm’s-length transactions, Form T1135 where specified foreign property costs more than $100,000, and a transfer pricing position that has to be documented contemporaneously rather than reconstructed under audit.
One thing we say plainly rather than leaving you to discover it. We advise on the Canadian side of your expansion. United States federal filings, and particularly state and local tax — nexus, registration, apportionment, sales tax and franchise taxes — go to your American adviser, and we will tell you when a question has crossed that line instead of answering it anyway.
Our Official Partners
Accounting That Understands How a US Expansion Actually Works
A US expansion does not arrive as one decision. It arrives as a sequence: a first American customer, then a representative on the ground, then a subsidiary, then intercompany charges nobody documented, then a lender asking for two years of statements that show the whole group. Each step changes what you owe and what you have to file, and the cost of getting the first one wrong compounds through all of them. At Gondaliya CPA, we understand that sequence and provide practical, industry-focused solutions across Ontario.
Stay Compliant and Minimize Your Cross-Border Tax
For a Canadian company expanding south, staying onside with CRA and paying the least legal tax across two countries are the same job. We keep every Canadian filing on schedule while claiming every credit, deduction and treaty benefit the law allows, so nothing is missed and nothing invites a reassessment.
Accounting & Tax Experts for Canadian Companies Expanding to the US
- AFFORDABLE + Registered CPA Firm
- Business and Corporate Tax Expert
- Small & Medium Business Expert
- Accounting, bookkeeping, and tax filing
- CPA (Chartered Professional Accountant)
- 1300+ 5-star Google reviews
- 30-Day Money-Back Guarantee
- 60-Day Fees Matching Policy
Why Choose Our Accounting Services for Canadian Companies Expanding to the US?
Tax Planning — Structure Before Formation
We model the entity decision and the LLC mismatch before anything is formed, frame the Article V position properly, and protect the $500,000 Small Business Deduction on the Canadian side.
Consulting — Intercompany Pricing
We set the management fee, royalty and cost allocation policy under ITA section 247, document it contemporaneously, and file the T106 so the position is defensible when it is tested.
CRA Representation — Transfer Pricing
When CRA challenges an intercompany charge, a withholding position or a foreign tax credit claim, we prepare the response and pursue relief on Form RC4288 where a prior error caused penalties.
Bookkeeping — Financing the Expansion
We produce CSRS 4200 statements that show intercompany balances and the translation basis transparently, which is what a lender or an investor funding a US expansion actually reads.
Google Reviews
Cross-Border Clients
Cross-Border Tax and Accounting Services in Ontario
Corporate Tax Filing (T2) for Companies Expanding to the US
Professional T2 preparation with American-source revenue separated, foreign tax credits claimed under ITA section 126, the foreign affiliate reported, and CRA compliance on every line.
Bookkeeping & Accounting for Cross-Border Groups
Books that carry intercompany balances explicitly, state the foreign-currency translation basis used, and keep Canadian and American revenue separated instead of merged into one total.
Payroll Services for Companies With US Staff
Canadian payroll handled properly with PD7A remittances, T4 and T4A slips filed on time, and the cross-border payroll question framed rather than answered by assumption.
GST/HST Filing for Companies Selling Into the US
AFFORDABLE HST filing with export supplies reviewed under ETA Schedule VI Part V, place of supply determined on what was supplied and where, and input tax credits claimed in full.
Tax Planning for US Expansion
Entity choice modelled before formation, the LLC mismatch quantified, repatriation planned, and the Small Business Deduction protected as the group grows across the border.
Corporate Catch-Up Filing for Cross-Border Groups
File overdue T2, T1134, T106 and T1135 years, rebuild the transfer pricing position you never documented, and get back into CRA compliance with accurate catch-up support.
CRA Audit Resolution for Cross-Border Transactions
Expert support on transfer pricing, withholding and foreign tax credit audits, handled with confidence from the first letter.
CPA Financial Statements (Notice to Reader) for Expanding Groups
CPA-compiled statements lenders and investors accept, showing intercompany balances, the translation basis and the investment in the subsidiary transparently across two fiscal years.
Incorporation Services for Cross-Border Structures
Full incorporation including NUANS, articles, share structure, and the section 85 rollover of your existing business, contracts and intellectual property into the company.
Catch-Up Bookkeeping Services for Cross-Border Groups
Months or years of intercompany transactions, foreign-currency invoices and American receipts reconstructed and reconciled, so your group’s revenue figure is finally accurate.
US Corporation & LLC Tax Filing Coordination
Coordination of the Canadian side with your American adviser’s filings, covering withholding, NR4 reporting, T1134 and T1135 obligations and the treaty position taken.
Voluntary Disclosure Program for Cross-Border Groups
Come forward on unfiled T1134, T106 or T1135 returns, undocumented intercompany charges or missed withholding, cancelling penalties through a Voluntary Disclosures Program application.
Accounting & Tax Services Tailored for Canadian Companies Expanding to the US
Real, practitioner-level CPA expertise for technology companies opening a first American office, manufacturers and distributors selling into the United States, professional services and engineering firms taking on American engagements, and ecommerce businesses holding inventory across the border — built for the structuring decision, not just the return.
- We prepare your T2 with GIFI on Schedule 100 and Schedule 125, separating Canadian-source revenue from American-source revenue so the foreign tax credit calculation has something defensible sitting behind it.
- We claim your foreign tax credit under ITA section 126 for tax actually paid to the United States on foreign-source income, computed by country and by income type rather than estimated as a single figure.
- We report the investment in your American subsidiary at a figure that ties to the Form T1134 filed for the same year, because a reviewer compares the two documents before asking you anything.
- We test interest on expansion borrowing against ITA subsection 18(4) and ITA section 18.2, because a debt-funded subsidiary engages both rules and neither one forgives a position taken without analysis.
- We keep the Small Business Deduction under ITA section 125 intact on the Canadian active income, watching the associated-corporation rules where the same shareholders also control the new American entity.
- We carry every intercompany balance as its own account rather than netting them into a single line, because a lender, a buyer and a CRA reviewer all read those balances before they read anything else.
- We state the foreign-currency translation basis you are using and apply it consistently across both years, so a group whose revenue moved with the exchange rate can still explain what actually changed.
- We separate Canadian-source and American-source revenue in the ledger from the first month, which is the one correction that makes the foreign tax credit and the treaty position computable rather than guessed.
- We record each management fee, royalty and cost allocation against the written intercompany agreement that supports it, so the transfer pricing file and the general ledger say the same thing.
- We capture American vendor invoices, state registrations and professional fees monthly and reconcile them, keeping the six years of records ITA section 230 requires and making sure no recoverable input tax credit is lost.
- We run your Canadian payroll properly, withholding income tax, CPP and EI and remitting on the PD7A by the 15th of the following month, because the late-remittance penalty reaches 10% on a graduated scale.
- We file your T4 slips and T4 Summary by the last day of February, reconcile them to the PD7A remittances made, and monitor Ontario payroll against the $1,000,000 Employer Health Tax exemption as you grow.
- We file T4A slips on the contractors who are genuinely contractors, tested against the Form RC4110 factors rather than on what the invoice says, because status is a question of fact in every case.
- We frame the cross-border payroll question rather than answering it by assumption: who employs your first American hire, which country’s payroll system applies, and what the social security coordination between the two countries means for them.
- We state no American payroll rate, threshold, wage base or filing deadline, and no certificate of coverage outcome, because those belong to an adviser licensed in that country and they change.
- We review each export supply against ETA Schedule VI Part V rather than assuming that selling to an American customer automatically puts the supply outside the tax, because that assumption is wrong often enough to matter.
- We determine place of supply on what was actually supplied and where it was supplied, not on the customer’s billing address, which is the single most common error on a file that has just started exporting.
- We file your GST34 returns on time with the export documentation retained behind each zero-rated supply, because the rate claimed is only as good as the evidence that the goods or services actually left.
- We monitor your taxable supplies against the $30,000 threshold over four consecutive calendar quarters where you are not yet registered, because an expansion usually crosses it in the same year it begins.
- We claim the input tax credits on your Canadian costs, including professional fees, software, travel and the accounting and legal work the expansion itself generates, which is where a surprising amount of recoverable tax sits.
- We model the entity decision before anything is formed, setting out what each of a branch, a corporation and an LLC would mean on the Canadian side, so the choice is made on numbers rather than on speed.
- We quantify the LLC mismatch specifically, because CRA generally treats a US LLC as a corporation while the United States treats it as transparent, and that disagreement is how foreign tax credit relief gets lost.
- We plan repatriation before the subsidiary is profitable rather than after, mapping how value comes home and what Part XIII withholding under ITA section 212 and NR4 reporting apply when it does.
- We set the salary and dividend mix for the owners, paying enough T4 salary to build RRSP room while the balance flows as dividends, keeping combined tax near the 12.2% Ontario small-business rate rather than 53.53%.
- We plan at least two years ahead so your shares qualify for the $1.25M Lifetime Capital Gains Exemption under ITA 110.6, and we flag that a growing foreign subsidiary can affect the active-business asset test.
- We reconstruct your cross-border transactions from intercompany invoices, bank records and the American entity’s own ledgers across the unfiled years, rebuilding the six years of records ITA section 230 requires.
- Late filing costs 5% of the balance owing plus 1% per month up to twelve months, so we file your oldest unfiled T2 first to stop the penalty compounding and limit the arrears interest CRA charges.
- We file the missing Form T1134 returns on the foreign affiliate and the missing Form T106 returns on non-arm’s-length transactions, because those information returns carry their own penalty regime regardless of tax owing.
- We file Form T1135 for each year specified foreign property cost more than $100,000, a filing that is missed constantly by groups who think of the subsidiary as an operation rather than as property.
- We rebuild the transfer pricing position across the missing years and document it as best the records allow, because an undocumented intercompany charge is the first thing an auditor reaches for.
- When CRA challenges an intercompany management fee or royalty, we produce the written agreement, the functional analysis and the contemporaneous documentation that ITA section 247 expects to exist already.
- When CRA questions a foreign tax credit claim, we produce the American tax actually paid, the income it was paid on and the by-country computation, because a credit claimed without that support does not survive.
- When CRA tests your withholding on payments out of Canada, we produce the Part XIII analysis, the NR4 slips and the basis for any treaty position taken, rather than explaining a rate after the fact.
- When CRA opens a full audit of the group, we manage the file and answer the revenue, intercompany and reporting queries inside the deadlines, so one year’s review does not expand across the prior years.
- We file the Notice of Objection within 90 days of a reassessment and pursue taxpayer relief on Form RC4288, cancelling penalties and interest where a prior adviser’s error caused them, and protecting your Tax Court rights.
- We prepare CSRS 4200 compilation engagement financial statements across two fiscal years, which is what a lender or an investor funding an expansion reads before it reads your projections.
- Your compiled statements show every intercompany balance explicitly rather than netted, because a receivable from the American subsidiary and a payable to it are two different facts about the group’s strength.
- We state the foreign-currency translation basis on the face of the statements, so a reader can tell how much of the change in revenue was growth and how much of it was the exchange rate.
- We present the investment in the American subsidiary separately and consistently across both years, tied to the Form T1134 filed, so the statements and the tax filings tell one coherent story.
- We deliver the compiled statements within 30 days of receiving your records and the year’s T2 figures, because a credit facility or a raise timed around an expansion does not wait for a slow accountant.
- We incorporate under the Ontario Business Corporations Act, giving you a separate legal entity and roughly the 12.2% Ontario small-business rate on active income against a top personal rate of 53.53%.
- We complete the section 85 rollover on Form T2057, transferring your existing business, contracts, intellectual property and equipment into the corporation at elected amounts and deferring the gain a straight sale would trigger.
- We set the share structure with the expansion in mind, because the ownership that works for a Canadian operating company is not always the ownership that works once an American subsidiary sits underneath it.
- We open the corporation’s CRA Business Number, HST and payroll accounts within the first 30 days and move customer billing across, so revenue lands in the entity that actually has to report it.
- We set the chart of accounts with intercompany balances, foreign-currency accounts and American-source revenue built in from day one, so the records accumulate correctly instead of being rebuilt under audit.
- We rebuild months or years of neglected books from intercompany invoices, foreign-currency bank statements and American vendor records, so a group that expanded faster than it accounted finally gets a ledger that ties.
- We unwind merged Canadian and American revenue into separate streams across the whole backlog, which is the single correction that makes the foreign tax credit and the treaty position computable at all.
- We reconstruct the intercompany account year by year from both sides, because a parent and a subsidiary whose intercompany balances do not agree is the fastest way to lose a lender’s confidence.
- We rebuild the capital pools from purchase invoices across Class 8 at 20%, Class 50 at 55%, Class 12 at 100% and Class 14.1 at 5%, which is almost always pooled incorrectly when we inherit a file.
- We recover input tax credits buried in unentered professional fee, software, travel and advertising invoices, because the year a company expands is the year its bookkeeping falls furthest behind.
- We coordinate the Canadian side of your group with your American adviser’s filings, so the treaty position, the intercompany pricing and the credit claims line up instead of contradicting each other across the border.
- We frame the permanent establishment question under treaty Article V and the allocation of business profits under Article VII, and we note that a treaty-based position on an American return is disclosed on Form 8833.
- We handle the Part XIII withholding under ITA section 212 on dividends, interest and royalties paid out of Canada with the NR4 reporting that follows, so nothing is missed when value moves.
- We manage the ITA section 116 clearance process where a non-resident disposes of taxable Canadian property, which arrives without warning when a shareholder or the group restructures mid-expansion.
- We state no American threshold, rate, registration requirement or state tax conclusion, and we say when a question has crossed into your American adviser’s territory instead of answering it anyway.
- We bring your group forward on Form T1134 returns never filed for the foreign affiliate, because that information return carries its own penalty regime whether or not any tax was ever owing on the affiliate.
- We disclose unfiled Form T106 returns on non-arm’s-length transactions with non-residents, which is the filing groups miss most often because the intercompany charges felt internal rather than reportable.
- We correct Form T1135 years where specified foreign property cost more than $100,000 and nobody filed, a gap that is very common among companies who thought of the subsidiary as an operation only.
- We file your submission on Form RC199 with a full reconstruction from intercompany invoices, bank records and both entities’ ledgers, so a group that outgrew its reporting is not left facing an arbitrary assessment.
- We confirm your disclosure is genuinely voluntary before CRA contacts you — the single condition that makes it valid — and secure roughly 50% interest relief on the older years, turning real exposure into a managed correction.
US Expansion Tax & Reporting Check
Six quick questions on your entity choice, your treaty position, your intercompany pricing, your foreign affiliate reporting, your withholding and your lender-ready statements. No fee shown.
1. Was your American entity choice modelled on both countries’ treatment before it was formed?
2. Has anyone framed whether you have a permanent establishment in the United States?
3. Are your intercompany charges documented contemporaneously under ITA section 247?
4. Have you filed Form T1134 and Form T106 for every year they were required?
5. Is your Part XIII withholding on payments out of Canada handled with NR4 reporting?
6. Do your statements show intercompany balances and the translation basis explicitly?
Free CPA Consultation for Canadian Companies Expanding to the US
Case Studies: Cross-Border Expansion Accounting & Tax
Toronto Software Company — An LLC Formed in an Afternoon, Unwound Over Two Years
The problem: A Toronto software company formed a US LLC because it was the fastest and cheapest entity available, and began billing American customers through it. Nobody had modelled what each country would say about it. The United States treated the LLC as fiscally transparent, taxing its income in the hands of its member. CRA treated the same entity as a corporation. The result was that the two countries disagreed about who had earned the income and who had paid the tax on it, and the company’s foreign tax credit claim under ITA section 126 had nothing coherent to attach to. It had also filed no Form T1134 and no Form T1135.
What we did: We documented the mismatch, modelled the alternatives on the Canadian side, worked with the company’s American adviser on the restructuring sequence, and filed the missing T1134 and T1135 returns through a Voluntary Disclosures Program application on Form RC199 before CRA raised it.
The result:
- Two years of unfiled T1134 and T1135 returns brought current
- Information-return penalties cancelled through the disclosure
- Foreign tax credit position made computable for the first time
Mississauga Manufacturer — Intercompany Charges Nobody Had Written Down
The problem: A Mississauga manufacturer had run an American sales subsidiary for four years. The Canadian parent charged it a management fee and recovered a share of engineering and administrative cost, and the amounts had been set by the controller each year on a basis nobody had recorded. There was no written intercompany agreement, no functional analysis and no documentation of why the charges were what they were. No Form T106 had ever been filed. When CRA opened a transfer pricing review under ITA section 247, the company had four years of charges and nothing to explain them with.
What we did: We rebuilt the intercompany position from invoices and both ledgers, prepared a functional analysis and a transfer pricing memorandum, put written agreements in place going forward, filed the missing T106 returns, and managed the CRA correspondence through to resolution.
The result:
- Four years of intercompany charges documented and defended
- Missing T106 returns filed and the reporting gap closed
- Written agreements and an annual documentation cycle now in place
Ottawa Engineering Firm — A Lender That Could Not Read the Group
The problem: An Ottawa engineering firm wanted a credit facility to fund American project work. Its statements merged Canadian and American revenue into one figure, netted the intercompany receivable and payable against each other into a single line, and never stated the foreign-currency translation basis used. The lender could not tell how much of two years of revenue growth was real work and how much was the exchange rate, could not see the group’s internal funding, and declined to proceed. The firm read it as a credit problem. It was a presentation problem.
What we did: We prepared CSRS 4200 compilation engagement financial statements across two fiscal years with Canadian and American revenue separated, each intercompany balance shown explicitly rather than netted, the translation basis stated on the face of the statements, and the investment in the subsidiary tied to the Form T1134 filed.
The result:
- Two years of compiled statements a lender could actually read
- Revenue growth separated from exchange rate movement
- Facility approved against the group rather than the parent alone
How We Work With Canadian Companies Expanding to the US
Our clear, efficient process ensures every step is transparent, building trust and long-term client relationships.
Kickoff (Document Request)
Collect prior T2 returns, any T1134, T106 and T1135 returns filed, the American entity’s formation documents and ledgers, intercompany agreements and invoices, customer contracts, borrowing agreements, and bank statements for both sides.
First 30 Days (Structure & Setup)
Model the entity position on both countries’ treatment, frame the Article V permanent establishment question, set the chart of accounts with intercompany and foreign-currency accounts, and identify every unfiled information return.
Monthly Close
Intercompany balances reconciled from both sides, Canadian and American revenue reported separately, translation applied consistently, management fees and cost allocations recorded against their agreements, and GST34 filed.
Quarterly Planning Review
Salary and dividend mix, repatriation timing and Part XIII withholding, transfer pricing documentation refreshed, interest tested against ITA subsection 18(4) and ITA section 18.2, and foreign tax credit position updated.
Year-End Close & T2 Filing
Trial balance, financial statements with intercompany balances and translation basis shown explicitly, Form T1134, Form T106 and Form T1135 prepared, T2 with GIFI and foreign tax credits, and CRA preparation.
Get Your US Expansion Structured Right Today
Affordable Pricing for Canadian Companies Expanding to the US
We believe in clear, upfront pricing so you know exactly what to expect. All fees include HST.
- Tax Preparation (Corporation) — From $400
- Tax Return Filing (Corporation) — From $400
- Tax Compliance Audit — FREE CRA audit support for our clients
- Tax Strategy — FREE for our clients
- Accounting Base Plan — From $100 per month
- Bookkeeping Management — Free for our Accounting clients
- Financial Reporting — Free for our Accounting clients
- Business Formation — Flat $35
- Incorporation Process — Flat $35
- Entity Setup Assistance — Flat $35
- Full-Service Payroll — From $125 per month
Payment is by Interac e-Transfer to info@gondaliyacpa.ca only. Security question: Not Applicable, as auto-deposit is enabled.
Meet Your Lead Cross-Border Accountant
Meet your lead cross-border accountant. As your international expansion and corporate tax adviser, you deal with the same two people every year.
What Our Clients Say
1300+ five-star reviews from technology companies, manufacturers, professional firms and expanding businesses across Ontario and Canada.
Serving Expanding Canadian Companies Across Ontario
Our CPA team provides specialized accounting and tax solutions for Canadian companies expanding into the United States throughout Ontario. We understand why the entity decision has to be modelled on both countries’ treatment before anything is formed, why a US LLC can leave foreign tax credit relief stranded, how every intercompany charge becomes a transfer pricing question under ITA section 247, which information returns follow a foreign affiliate every year, and what a lender funding an expansion actually reads in your statements.
Toronto (ON)
55 Queen St E Ste 1205, Toronto, ON M5C 1R6, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Mississauga (ON)
2100 Camilla Rd #716, Mississauga, ON L5A 2J8
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Brampton (ON)
4 Starhill Crescent, Brampton, ON L6R 2P9, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Scarborough (ON)
24 Clementine Square, Scarborough, ON M1G 2V7, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Vaughan (ON)
19 Cabinet Crescent, Woodbridge, ON L4L 6H9, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Oshawa (ON)
210 Durham St, Oshawa, ON L1J 5R3, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Ottawa (ON)
2090 Neepawa Ave a314, Ottawa, ON K2A 3L6, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Etobicoke (ON)
60 Stevenson Rd #1601, Etobicoke, ON M9V 2B4, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Hamilton (ON)
70 Starling Dr, Hamilton, ON L9A 0C5, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Guelph (ON)
1155 Gordon St, Guelph, ON N1L 1S8, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Windsor (ON)
4387 Guppy Ct, Windsor, ON N9G 2N8, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
North York (ON)
150 Graydon Hall Dr #912, North York, ON M3A 3B2, Canada
+1 (647) 212-9559
9:00 AM – 8:30 PM (Mon – Sun)
Cross-Border Expansion Accounting & Tax FAQs
Related Industries We Serve
US Corporation & LLC Tax Filing
- Cross-border return coordination
- Withholding and NR4 reporting
- T1135 and T1134 obligations
Accountant for Foreign Shareholders of Canadian Corporations
- Non-resident shareholder structuring
- Part XIII withholding and NR4
- Section 116 clearance certificates
Accountant for Scale-Up Companies
- Growth-stage financial reporting
- Investor and lender statements
- Corporate tax planning and advisory
Virtual International Tax Services
- Remote cross-border tax support
- Treaty position documentation
- Foreign reporting compliance
Cross-Border Expansion Accounting & Tax Done Right.
Built for the decision rather than the return: the entity choice modelled on both countries’ treatment before anything is formed, the US LLC mismatch quantified instead of discovered two years later, the permanent establishment question framed under treaty Article V and Article VII, every intercompany charge priced and documented contemporaneously under ITA section 247 with Form T106 filed, Form T1134 on the foreign affiliate and Form T1135 where specified foreign property costs more than $100,000, Part XIII withholding under ITA section 212 with NR4 reporting when value comes home, foreign tax credits computed under ITA section 126 rather than estimated, and CSRS 4200 statements that show intercompany balances and the translation basis a lender actually reads. We advise on the Canadian side and say so. AFFORDABLE flat fees, no hourly billing. Licensed CPA Ontario. 1300+ five-star reviews. 30-Day Money-Back Guarantee.