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Gondaliya CPA

Corporate Tax Filing Experts

Tax Accountant for Cross-Border E-Commerce Sellers in Ontario and Across Canada

Selling to buyers in another country changes what your corporation has to report, not only what it charges at checkout. Regulation 105 obliges you to hold back 15% from a fee paid to a non-resident who renders services in Canada — the American contractor who flies into Ontario for a week of on-site work — while a designer or an affiliate working entirely from abroad sits outside that rule altogether, and Part XIII tax with NR4 reporting is a separate regime covering royalties and certain other amounts. Add Form T1135 once specified foreign property costs more than $100,000, Form T1134 once a US company of yours becomes a foreign affiliate, Form T106 once non-arm’s-length dealings with non-residents pass $1,000,000, and section 247 pricing on intercompany sales, and the reporting half of the file outweighs the sales-tax half. Whether you ship from Ontario to US buyers, hold stock in an American warehouse or get paid in three currencies, we take on the returns, the elections and the T2 — with AFFORDABLE flat fees.

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AFFORDABLE Cross-Border E-Commerce Seller Tax Accountant

Ask a cross-border seller what tax goes on an order shipping to Ohio and most of them can answer. Ask what the corporation has to report because that order exists, and the room goes quiet. Those are not the same question, and only one of them ends up on a T2. Money leaving Canada to somebody who is not resident here may carry a withholding obligation, and which obligation depends entirely on where the work was performed: Regulation 105 asks for 15% to be held back from fees paid to a non-resident who renders services in Canada, and it does not reach a contractor who never sets foot in the country. Stock resting in a warehouse in Kentucky is still your stock, and subsection 10(1) of the Income Tax Act still measures it at cost or fair market value, whichever is the lower. A US company opened to make returns easier becomes a foreign affiliate with an information return attached, and selling your own goods across to that company puts section 247 pricing on the table. None of that is set off by the checkout page; all of it is set off by the structure. Those are the files we take on. AFFORDABLE flat fees, filings that land inside their deadlines, and a tax bill held to what the legislation actually requires.

As a cross-border e-commerce accountant we act for Ontario sellers shipping direct to American buyers, sellers holding inventory in US fulfilment centres, sellers running a second selling entity outside Canada, and sellers whose payouts land in a currency they do not report in. We stay on the file month to month rather than appearing once a year with a return to sign, and we tell you which information returns your structure has genuinely triggered and which ones it has not.

Hand us the reporting side and get back to selling.

Gondaliya CPA team - accounting and tax services for cross-border e-commerce sellers

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Accounting That Understands How a Cross-Border E-Commerce Seller Actually Works

Crossing a border adds obligations that never appear in a sales report. Money paid to people outside Canada may or may not carry withholding, and the answer turns on where they did the work rather than on where they live. Stock held abroad is still on your balance sheet. A foreign company files nothing to CRA itself, but you file about it. Payouts a platform has already converted leave an exchange difference that belongs in the books. Gondaliya CPA exists for exactly that set of problems, and we work alongside sellers everywhere in Ontario.

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Where the Work Was Done Decides It

Regulation 105 follows the place a service was performed, never the payee’s mailing address. A US contractor on site in Ontario is inside it. Somebody working from abroad is not inside it at all.

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Your Stock, Somebody Else’s Warehouse

Inventory in an American fulfilment centre remains yours, valued under subsection 10(1) at the lower of cost and fair market value. The figure customs used answers a different question.

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A Subsidiary Is a Reporting Event

Opening a US company to smooth fulfilment creates a foreign affiliate, and Form T1134 arrives with it. Convenience on one side of the line is paperwork on the other.

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A Payout Is Not Your Revenue

A platform converts, deducts and then deposits. Gross order value, platform fees and the exchange difference are three numbers; the sales-tax mechanics sit on our cross-border selling tax rules page.

Stay Compliant and Minimize Your Cross-Border E-Commerce Tax

A seller with customers on both sides of the line does not have two jobs here. Getting the filings in when they are due and keeping the bill down to what the legislation asks for are the same piece of work, and we keep the returns and the information slips on schedule while claiming every credit, cost and exchange loss the T2 allows.

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Regulation 105, and What It Does Not Touch

Fees paid to a non-resident are the item sellers get wrong most often, because they reach for the payee’s address instead of the place of performance. Regulation 105 requires 15% to be withheld from a fee paid to a non-resident who renders services in Canada. The words doing the work there are in Canada. An American product photographer who flies into Toronto for a two-day shoot is inside the rule; so is a US developer who spends a fortnight in your Ontario office. A designer in Lisbon who never leaves Lisbon, an affiliate in Ohio who posts a link, an influencer filming in Los Angeles — not one of them is within Regulation 105, because not one of them performed a service in Canada. Holding 15% back from those invoices is not caution; it is retaining money you had no authority to retain, and you are then the party who has to unwind it. Part XIII tax with NR4 reporting is a separate regime, and it is the one that reaches royalties and certain other amounts paid out of Canada — the licence fee on artwork you print on your packaging, say, rather than a bill for work somebody did. The two are answered one after the other, payee by payee.

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CRA Obligations for Cross-Border E-Commerce Sellers

A cross-border seller’s CRA file is a short annual list, plus a set of information returns most sellers have never been shown. An order that finishes at a Canadian address is a taxable supply carrying 13% in Ontario; the credits on your Canadian spending come back against it; and the moment taxable revenue crosses $30,000, measured across four consecutive calendar quarters, registration is no longer a choice. Exports of goods are generally zero-rated under Part V of Schedule VI to the Excise Tax Act, subject to its conditions and to holding evidence. On the income-tax side, Form T1135 is required where specified foreign property has a total cost above $100,000; Form T1134 reports a foreign affiliate or controlled foreign affiliate, which is what a wholly owned American company becomes; Form T106 reports non-arm’s-length dealings with non-residents once they pass $1,000,000; and section 247 expects contemporaneous documentation behind the price you charge your own US entity. On the payroll side the sequence is fixed: WSIB registered before the first person starts, income tax, CPP and EI withheld and remitted against the PD7A each period, T4 slips to employees and T4A slips to genuine subcontractors, and the T4 Summary lodged by the last day of February. Remit late and the penalty is graduated, rising as high as 10%. Ontario employer health tax applies once payroll passes $1,000,000. And section 230 of the Income Tax Act puts a six-year floor under the whole record set.

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Year-End Deliverables for Cross-Border E-Commerce Sellers

A cross-border selling corporation closes its year on a trial balance and a set of statements that will stand up to a lender’s reading and a reviewer’s. Inventory is stated on its subsection 10(1) basis wherever the units physically are, with stock in an American fulfilment centre and stock still on the water both counted rather than assumed away. Balances held in another currency are translated at the closing rate and the exchange difference is shown instead of buried. Where the section 261 functional currency election has been made and the company reports in a qualifying currency, the statements and the return follow that currency consistently. Revenue is presented by destination so the Canadian-delivered line agrees with the HST returns already filed, and platform fees, shipping recoveries and refunds are each visible rather than netted into one number. Finally the T2 and its GIFI have to agree with the HST returns already filed and with any Form T106, T1134 or T1135 travelling alongside.

Accounting & Tax Experts for Cross-Border E-Commerce Sellers

Gondaliya CPA cross-border e-commerce accounting expertsGondaliya CPA cross-border e-commerce tax experts
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Why Choose Our Accounting Services for Cross-Border E-Commerce Sellers?

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Tax Planning — Structure & Elections

We model whether a US company earns its keep before it exists, because the convenience it buys arrives with Form T1134 attached, and we test the section 261 currency election against how you are actually paid. The $500,000 small-business limit stays protected.

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Consulting — Payouts, Currency & Cost

Our bookkeeping splits gross order value from platform fees and from the exchange difference on each payout, holds inventory on its subsection 10(1) basis wherever it sits, and shows the margin that survives shipping and currency.

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CRA Representation — Withholding & Pricing

When CRA asks why nothing came off a payment abroad, or what supports the price you charged your own US company, we answer with the contract, the place of performance and the section 247 documentation. Form RC4288 is used to ask for relief where an earlier mistake is what generated the penalties.

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Bookkeeping — Two Countries, One Ledger

Orders, payouts, refunds, fulfilment fees and intercompany charges are posted as they happen and by destination, so the year-end return records what occurred rather than reconstructing it.

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Cross-Border E-Commerce Tax and Accounting Services in Ontario

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Corporate Tax Filing (T2) for Cross-Border E-Commerce Sellers

T2 preparation with revenue split by destination, stock held abroad valued under subsection 10(1), the section 126 foreign tax credit claimed, and Form T106, T1134 or T1135 filed where your structure calls for it.

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Bookkeeping & Accounting for Cross-Border E-Commerce Sellers

Gross order value, platform fees and payout exchange differences posted separately, intercompany charges logged as they arise, and statements built on records that reconcile.

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Payroll Services for Cross-Border E-Commerce Sellers

Payroll for your Ontario team: WSIB registered before anybody starts, remittances against the PD7A, T4 and T4A slips filed on time, and non-resident payees assessed on their own footing.

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GST/HST Filing for Cross-Border E-Commerce Sellers

AFFORDABLE HST filing with 13% on Canadian-delivered orders, exports reviewed against Part V of Schedule VI, and every credit on your Canadian costs recovered.

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Tax Planning for Cross-Border E-Commerce Sellers

Year-end date, the small-business limit, whether an American entity is worth the reporting it brings, and the section 261 currency election modelled first.

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Corporate Catch-Up Filing for Cross-Border E-Commerce Sellers

File overdue T2 and HST years, rebuild revenue and currency from payout reports, and pick up the information returns nobody filed.

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CRA Audit Resolution for Cross-Border E-Commerce Sellers

Support on withholding, export evidence, related-party pricing and inventory reviews, handled from the first letter to the last.

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CPA Financial Statements (Notice to Reader) for Cross-Border E-Commerce Sellers

CPA-compiled statements lenders accept, carrying inventory wherever it physically sits, foreign balances translated, and any American subsidiary presented properly.

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Incorporation Services for Cross-Border E-Commerce Sellers

Incorporation handled throughout — NUANS search, articles, share classes — together with the section 85 rollover that brings stock, packing equipment and the storefront across.

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Catch-Up Bookkeeping Services for Cross-Border E-Commerce Sellers

Months or years of payout reports, fulfilment invoices, supplier bills and currency conversions reconstructed, so the ledger finally agrees with the platform.

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US Corporation & LLC Tax Filing for Cross-Border E-Commerce Sellers

Where an American entity, a US warehouse or a non-resident shareholder is in the picture, we work through the permanent establishment question and the reporting that follows.

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Voluntary Disclosure Program for Cross-Border E-Commerce Sellers

Withholding never remitted, foreign property never reported, information returns never filed — disclosed on your own initiative, with the penalties lifted under the Voluntary Disclosures Program.

Accounting & Tax Services Tailored for Cross-Border E-Commerce Sellers

Real, practitioner-level CPA expertise for Ontario sellers shipping direct to American buyers, sellers holding inventory in US fulfilment centres, sellers operating a company on the other side of the line and sellers paid in a currency they do not report in — built for a business whose hardest questions are about structure and reporting rather than the rate at checkout.

  • The GIFI behind your T2 is laid out on Schedule 100 and Schedule 125 so that Canadian-delivered orders, export orders, platform fees, shipping recoveries and refunds each hold a line of their own instead of one blended figure.
  • Under subsection 10(1) of the Income Tax Act, inventory is carried at cost or fair market value, whichever is lower, and the duty and inbound freight are part of that cost wherever the units happen to sit.
  • Value for duty is a customs measure for a customs purpose, not the same number as cost for inventory, so we keep the two apart rather than treating a broker’s figure as the tax basis.
  • Where US tax has genuinely been paid we claim the section 126 foreign tax credit, while saying plainly that a credit has limits rather than promising that every item escapes being taxed in both places.
  • On Schedule 8 the pools split by asset: packing benches and shelving in Class 8 at 20%, a van in Class 10 at 30%, storefront laptops in Class 50 at 55%, and licensed software in Class 12 at 100%.
  • A marketplace payout is a net figure, so we post the gross order value, the fees the platform took off it and the exchange difference on conversion as three separate amounts rather than banking the deposit as revenue.
  • A platform that converts for you moves the reported margin in a way nobody notices until the year-end, so the difference between the order-day rate and the deposit-day rate is recorded as it arises rather than plugged later.
  • Which Incoterm a supplier sells on decides who carries the freight and the insurance, and that decides what belongs inside the cost of your goods, so we read the terms before the invoice gets coded.
  • Charges between your company and its American entity are logged with a date, an amount and a reason while everybody still remembers why; section 247 documentation assembled two years later persuades nobody.
  • Section 230 of the Income Tax Act wants the records held six years, and in this trade that takes in the platform settlement files, which a seller cannot get back once the download window closes.
  • Employees on the Ontario payroll get T4 slips and genuine Canadian subcontract suppliers get T4A slips, which means every dollar the company claimed as a wage or a contract cost is traceable from the ledger to a filed slip.
  • The payroll itself runs through us: deductions calculated, the remittance lodged against the PD7A on time, and the graduated late-remittance penalty, which tops out at 10%, kept away from a business that already has enough moving parts.
  • February’s last day is the date for the T4 slips and the T4 Summary, and both get tied back to what was actually remitted, since that reconciliation is the first test CRA applies to a payroll account.
  • WSIB coverage is registered from the first hire, because a packing and shipping operation moving stock on pallet jacks and cutting boxes all day is not a place to carry that exposure with nothing behind it.
  • Once a year’s payroll clears $1,000,000 the Ontario employer health tax applies, and a seller who builds a fulfilment crew through one exceptional season crosses that line without registering that it happened.
  • An order delivered to a Canadian address is taxable, at 13% in Ontario, and the registration trigger — $30,000 of taxable revenue measured over four consecutive calendar quarters — is reached sooner than most first-year storefronts assume.
  • Exports of goods are generally zero-rated under Part V of Schedule VI to the Excise Tax Act, subject to conditions and to keeping evidence; our cross-border selling tax rules page works that side through and this one does not repeat it.
  • We claim input tax credits on advertising, software, professional fees, packaging and Canadian freight, which is where an export-weighted seller recovers real cash on returns that collect very little tax.
  • Where your group’s American company supplies digital products or services to consumers in Canada, the simplified GST/HST registration regime in force since 1 July 2021 is aimed at it as a non-resident supplier, not at you.
  • Every HST period is reconciled to the revenue on the T2 by destination, because a return showing Canadian sales the corporate return cannot account for is the mismatch a reviewer opens with.
  • The fiscal year-end is chosen to sit clear of your heaviest selling weeks, which means the currency position and the stock count are settled when somebody in the business still has time for them.
  • The owners’ remuneration is split deliberately between T4 salary and dividends, salary sized to keep registered contribution room building and dividends taking the rest, which lands the combined cost well under a top personal rate of 53.53%.
  • Active business income is kept inside the $500,000 limit that section 125 puts the roughly 11.2% Ontario combined rate (from July 1, 2026) on, and we watch the associated-corporation rules where the same family also owns the American entity.
  • Before an American subsidiary exists we model what it earns against what it costs, because a foreign affiliate brings Form T1134 and passive earnings inside it raise the foreign accrual property income question.
  • The $1.275M exemption under section 110.6 is not something arranged in the month before a sale; the share conditions and the asset tests behind it want years of lead time and a balance sheet without passive clutter in it.
  • We rebuild revenue by destination across the unfiled years out of payout reports, bank deposits and whatever the platform still holds, then send the earliest year in first so the penalty stops compounding.
  • Filing a T2 late costs a percentage of the balance owing at once and a further monthly charge for as long as it stays unpaid, which is why the oldest year always goes in first.
  • We pick up Form T1135 for each open year in which specified foreign property cost more than $100,000, because that obligation stands alone and is penalised whether or not any tax was owing.
  • We file the late Forms T106 and T1134 the structure required, so an American company that has existed quietly for three years stops sitting on the file as an unreported foreign affiliate.
  • The missing years are regularised through a Voluntary Disclosures Program submission on Form RC199, with Form RC4288 used for taxpayer relief where penalties grew out of a mistake rather than a choice.
  • When CRA asks why nothing was held back from a payment to a non-resident, we answer with the engagement contract and the place of performance, because Regulation 105 turns on where the service was rendered.
  • Where withholding genuinely was required and got missed, the payer is who CRA looks to, so the file is answered with amounts and dates, an objection goes in inside the ninety-day window if needed, and relief is sought on Form RC4288.
  • Where the price charged to your own American company is questioned we produce the section 247 documentation, the comparables behind it and the contemporaneous record, so the discussion runs on evidence.
  • Where zero-rated treatment on an export order is challenged we produce the shipping and delivery evidence, because that treatment stands on what can be shown, not on where the invoice was addressed.
  • Under subsection 152(7) of the Income Tax Act an assessment can be raised on whatever figure CRA thinks fit if the return and its records never appear, which is why every deadline in a review letter gets met.
  • No bank advances against a spreadsheet and a settlement export, so what goes to the credit file is a CSRS 4200 compilation engagement, two fiscal years side by side, with the notes that make it readable.
  • The statement of financial position carries inventory on its subsection 10(1) basis wherever the units are, with stock in an American fulfilment centre and stock in transit both counted rather than assumed.
  • Balances held in another currency are translated at the closing rate and the exchange difference disclosed, so a strong year is not quietly a currency movement that reverses in the next one.
  • Where the group holds an American company, the investment in it is presented for what it is rather than folded into other assets, which is the first thing a reviewer of the group looks for.
  • Thirty days from the point your records and the year’s T2 figures reach us is when the statements land, because a supplier’s credit terms and a bank’s conditional offer both carry expiry dates.
  • Incorporation puts limited liability between the owners and a product or delivery claim raised in another country, and it brings the first $500,000 of active business income down to roughly 11.2% combined in Ontario.
  • Stock, packing equipment, the storefront and the domain all transfer in under a section 85 election, Form T2057, with elected amounts set by the owners so no gain crystallises simply because assets changed hands.
  • The Business Number, the HST account and the payroll account are opened in the corporation’s name, and the storefront, payment-processor and carrier logins are switched over to it, so deposits land in the entity that files the returns.
  • We decide with you whether an American entity belongs in the picture at all, because incorporating one is a reporting decision as much as an operating one and Form T1134 follows it from then on.
  • Opening balances for Class 8, Class 10, Class 12 and Class 50 are struck off the rollover figures themselves, which means year one has a real capital cost schedule behind it instead of a guess made later.
  • Neglected books get rebuilt out of payout reports, bank deposits, fulfilment invoices, supplier bills and carrier statements, so a business two seasons behind finishes with a ledger a return can actually be filed from.
  • We separate gross order value, platform fees and the exchange difference on every payout across the missing months, which is the part of these books we almost always find collapsed into one number.
  • We rebuild inventory on its subsection 10(1) basis at each missing year-end, counting units in a foreign warehouse and units in transit rather than treating anything outside the country as gone.
  • We rebuild the Class 8, Class 10, Class 12 and Class 50 balances from the purchase invoices, so the capital cost allowance on the caught-up returns is claimed off figures instead of off recollection.
  • We recover input tax credits left in advertising, software, professional fee and packaging invoices never entered, which on an export-weighted seller is usually the largest single recovery in the work.
  • The first question is whether anything is owed at all, not which form to file, and it starts with permanent establishment: a fixed place of business through which an enterprise carries on business, as Article V of the Canada–United States tax treaty frames it.
  • Whether one exists is a facts-and-circumstances question, answered on what the business genuinely does in the United States rather than against a threshold, so we work the facts and write the position down rather than offering a bright line.
  • US state income tax is its own subject and not the sales-tax registration question; a state can reach the income of a business that has no duty to collect its sales tax, and the mismatch runs both ways.
  • Where the group holds an American company we file Form T1134 for it as a foreign affiliate or controlled foreign affiliate, and we test whether its earnings land in foreign accrual property income rather than assuming they are active.
  • Form T1135 goes in where specified foreign property has a total cost above $100,000, a line a seller funding an American entity or holding a working balance abroad crosses more easily than expected.
  • We bring the company forward where withholding on a non-resident’s Ontario work was never remitted, correcting the position on your own terms rather than on a reviewer’s, which is the point of going first.
  • We disclose foreign property that should have been on Form T1135 and an American company that should have been on Form T1134, because those obligations are penalised in their own right.
  • The submission goes on Form RC199 with the years rebuilt from payout reports, bank records and intercompany invoices, so the numbers under discussion are yours rather than an estimate arrived at in the absence of any.
  • Where Part XIII tax on a royalty paid out of Canada was never withheld and no NR4 return was filed, we put that right inside the same submission rather than leaving it to surface later.
  • We confirm the disclosure is still voluntary, complete and at least a year past due before anything is sent, because CRA reaching you first is precisely what takes the relief off the table.

Cross-Border Structure & Reporting Check

Six questions on withholding from money paid abroad, foreign property and foreign affiliate reporting, related-party dealings, the currency you report in, stock held outside Canada and whether incorporating is overdue. No fee shown.

1. Has anybody checked whether a fee you paid a non-resident was for work performed inside Canada?

2. Is Form T1135 filed for every year your specified foreign property cost more than $100,000?

3. If you own a company outside Canada, has Form T1134 been filed for it?

4. Do dealings with your own American entity have pricing documentation behind them?

5. Are payout exchange differences recorded rather than absorbed into revenue?

6. Is your cross-border e-commerce business incorporated?

Free CPA Consultation for Cross-Border E-Commerce Sellers

Case Studies: Cross-Border E-Commerce Accounting & Tax

Windsor Auto-Accessory Seller — An American Company and the T106 Threshold

The problem: A Windsor seller of interior and exterior car accessories opened an American company so returns from US buyers could be handled on that side of the river. Within two years the Canadian corporation was shipping roughly $1.6 million of stock a year across to that subsidiary. No Form T106 had ever gone in, no Form T1134 either, and the price the goods moved at had been set by copying the domestic wholesale list because nobody had thought to ask.

What we did: We filed Form T106 for each year in which the $1,000,000 reporting threshold had been passed, filed the outstanding Form T1134 returns for the subsidiary as a foreign affiliate, and built section 247 documentation supporting the intercompany price, then brought the position forward under a disclosure.

The result:

  • Three years of Form T106 and Form T1134 filed
  • Intercompany pricing documented under section 247
  • Penalty exposure removed by going forward voluntarily

Oshawa Outdoor-Gear Brand — Reporting in the Currency It Actually Earns

The problem: An Oshawa outdoor-gear brand took about four fifths of its revenue in US dollars, bought its stock in US dollars, and kept a working balance in an American bank account. All of it was being converted into Canadian dollars at whatever rate the bookkeeper happened to find that week, which threw up exchange gains and losses of a size that had nothing to do with how the brand had traded. Two consecutive years swung so hard the owner could not tell whether the business had made money.

What we did: We tested whether the section 261 functional currency election suited the business, filed the election on Form T1296 within the prescribed time, and rebuilt the books so the company reports in the currency it earns, with the HST returns still reconciled in Canadian dollars.

The result:

  • Section 261 election filed on Form T1296
  • Currency noise separated from trading results
  • Two earlier years restated on a consistent basis

Woodbridge Homeware Seller — The Contractor Who Flew In

The problem: A Woodbridge homeware seller paid an American photographer and an American merchandiser to spend eleven days in its Ontario premises shooting a catalogue and resetting the storefront. Both invoices were paid gross. Nothing was held back, because somebody had told the owner that people outside Canada get paid gross, and in the same period the company had quite correctly paid an overseas graphic designer gross for work done entirely from abroad.

What we did: We identified the two engagements performed in Canada, calculated and remitted the Regulation 105 withholding on those fees with the travel and engagement records behind it, confirmed that the designer working from abroad was outside the rule altogether, and built a payee review into the payment process.

The result:

  • Withholding settled on the two engagements performed in Ontario
  • Payments for work done abroad confirmed outside Regulation 105
  • A place-of-performance check built into every foreign invoice

Our Simple Process

How We Work With Cross-Border E-Commerce Sellers

Know Exact Fees within 2 Minutes NOW

Our clear, efficient process ensures every step is transparent, building trust and long-term client relationships.

Here’s a simplified process approach:
Step 1

Kickoff (Document Request)

Prior T2 returns, platform and marketplace payout reports month by month, payment-processor statements, supplier and fulfilment invoices, inventory counts by location including stock held abroad, contracts with every non-resident you pay, and bank statements in each currency.

Step 2

First 30 Days (Cleanup & Setup)

QuickBooks Online or Xero set up with multi-currency against your storefront and marketplace feeds, revenue split by destination, inventory rebuilt on its subsection 10(1) basis by location, and the Class 8, 10, 12 and 50 balances reconstructed from invoices.

Step 3

Monthly Close

Gross order value, platform fees and payout exchange differences posted separately, intercompany charges captured as they arise, HST by destination, payroll reconciled to the PD7A, and every new foreign payee tested for place of performance.

Step 4

Quarterly Planning Review

Salary and dividend mix, the small-business limit, the currency position, whether every information return your structure triggers is on track, and whether an American entity still earns what it costs.

Step 5

Year-End Close & T2 Filing

Trial balance, statements with inventory counted wherever it sits and foreign balances translated, T2 with GIFI, Form T106, T1134 and T1135 where required, and the file ready for CRA.

Get Your Cross-Border E-Commerce Taxes Done Right Today

Transparent Pricing for Cross-Border E-Commerce Sellers

Affordable Pricing for Cross-Border E-Commerce Sellers

Know Exact Fees within 2 Minutes NOW

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 E-Commerce Accountant

One team, one file, year after year: the payout accounting, whichever information returns your structure sets off, and the corporate return itself.

Sharad Gondaliya CPA

Sharad Gondaliya, CPA

Principal

Bio

647-212-9559
sharad@gondaliyacpa.ca

Vandana Goel CPA

Vandana Goel, CPA

Accounting Specialist

Bio

647-250-0242
vandana@gondaliyacpa.ca

What Our Clients Say

1300+ five-star Google reviews sit behind this page, written by people running online stores, marketplace accounts and product brands across Ontario and further afield.

Serving Cross-Border E-Commerce Sellers Across Ontario

We act for cross-border sellers throughout Ontario, from one storefront shipping a few American orders a week to groups running a Canadian company and a second one across the line. The value we add sits where this trade normally goes wrong: telling a payment abroad that carries withholding from one that plainly does not, identifying the information returns your structure has actually triggered, and locating your stock for tax purposes.

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

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Vaughan (ON)

19 Cabinet Crescent, Woodbridge, ON L4L 6H9, Canada

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Oshawa (ON)

210 Durham St, Oshawa, ON L1J 5R3, Canada

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Ottawa (ON)

2090 Neepawa Ave a314, Ottawa, ON K2A 3L6, Canada

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60 Stevenson Rd #1601, Etobicoke, ON M9V 2B4, Canada

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North York (ON)

150 Graydon Hall Dr #912, North York, ON M3A 3B2, Canada

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Cross-Border E-Commerce Accounting & Tax FAQs

Do I have to withhold tax when I pay a US contractor?
It depends on where the work was done, and on nothing else. Regulation 105 requires 15% to be withheld from a fee paid to a non-resident who renders services in Canada. An American photographer who flies into Ontario for a two-day shoot, or a US developer who spends a fortnight in your office, is inside the rule, and 15% comes off the fee before it is paid. What is held back is remitted and reported, and it is not the non-resident’s final tax — it is money held against whatever Canadian liability turns out to exist, which they settle on their own return. The obligation sits on you as payer, so we read the engagement rather than the invoice.
Does Regulation 105 apply to an overseas designer or influencer?
No. This is the most common cross-border error we correct, and it runs in the over-cautious direction as often as the other way. Regulation 105 reaches a non-resident who renders services in Canada. A designer working from Lisbon, an affiliate in Ohio who posts a link, an influencer filming in Los Angeles — not one of them performed a service in Canada, so not one of them falls within Regulation 105. Holding 15% back from those invoices is not prudence; it is retaining money you had no authority to retain. The test is the place of performance: not the payee’s address, not the currency, not where your customers are.
Is Part XIII withholding the same thing as Regulation 105?
No, and keeping the two apart matters. They are separate regimes with separate triggers. Regulation 105 is about fees for services rendered in Canada. Part XIII withholding, with NR4 reporting, reaches royalties and certain other amounts paid to non-residents — the licence fee on artwork you print on your packaging, say, rather than a bill for work somebody performed. One payment can raise the first question, the second, or neither, and answering one tells you nothing about the other. Where a treaty applies it can reduce the Part XIII rate, which is a reason to hold the payee’s residency certification before the money leaves.
Can I report in US dollars if that is what I actually earn?
Possibly. Section 261 of the Income Tax Act lets a corporation report in a qualifying currency instead of Canadian dollars, and the election is made on Form T1296, which has to be filed within the prescribed time rather than whenever it occurs to somebody. It earns its place for a seller whose revenue, stock purchases and bank balances are overwhelmingly in one foreign currency, because it stops exchange movements on ordinary trading from dominating the reported result. It is not a shortcut, and the Canadian-delivered side still reconciles to the HST returns in Canadian dollars.
When do I have to file Form T1135?
Where the total cost of your specified foreign property is more than $100,000. That is a cost threshold rather than a market-value threshold, and it catches more sellers than they expect: money put into an American entity, a working balance sitting with a foreign bank or payment processor, foreign shares held personally. The obligation exists whether or not any tax was owing on the property, and the penalty regime is aimed at the failure to file. Note too that Form T1135 is not Form T1134: filing one does not deal with the other.
I set up a US company to make fulfilment easier. What does that change?
It makes you the Canadian parent of a foreign affiliate, and Form T1134 comes with that. The return reports the foreign affiliate or controlled foreign affiliate to CRA, and the obligation exists because you own the company, not because it earned anything in particular. Where the subsidiary holds passive earnings instead of running an active business, the foreign accrual property income rules come into play and some of those earnings can be pulled into your Canadian income before a dollar is paid up to you. And everything the Canadian company sells to or buys from that subsidiary is a related-party transaction, which is where section 247 and Form T106 begin.
What is Form T106, and how do I price sales to my own US company?
Form T106 is the information return for non-arm’s-length transactions with non-residents, required once the reportable total for the year passes $1,000,000. That figure arrives quickly when a Canadian company moves its own stock across to its own subsidiary, because it is the flow that counts and not the profit inside it. On the pricing itself, section 247 expects the price between related parties to be the price parties dealing at arm’s length would have used, supported by contemporaneous documentation written while the arrangement is running rather than assembled once a question has arrived. Copying your domestic wholesale list is a starting point, not a defence.
Is the customs value of my goods the same as their cost for tax?
No, and treating them as interchangeable is a common and expensive shortcut. Subsection 10(1) of the Income Tax Act values inventory at the lower of cost and fair market value, and the duty and freight paid to bring the goods in form part of that cost. Value for duty is a different measure, worked out under customs legislation for a customs purpose, and it was never designed to be your tax basis. Which Incoterm the supplier sold on matters here too, because it settles who was carrying the freight and the insurance. For completeness, net realizable value is the accounting measure under ASPE and not the statutory tax test.
Do I charge HST on orders going to the United States?
Generally not, and not by accident: exports of goods are zero-rated rather than merely untaxed. Part V of Schedule VI to the Excise Tax Act generally zero-rates exports of goods, subject to its conditions and to keeping evidence that the goods genuinely left. Because this page is about how the business itself is taxed, structured and reported, the sales-tax mechanics are dealt with in depth on our e-commerce accounting and tax page. The short version is that your Canadian-delivered orders carry 13% in Ontario, your export orders generally do not, and your Canadian costs still generate input tax credits either way.
Does my US company have to register for GST/HST when it sells back into Canada?
Good question, and a different one from your own registration. The simplified GST/HST registration regime, in force since 1 July 2021, applies to non-residents supplying digital products and services to consumers in Canada. So if the American entity in your group sells software, downloads, memberships or other digital supplies to Canadian consumers, the regime is aimed at that entity as a non-resident supplier, and the registration is its own rather than yours. It does not apply to the Canadian company’s own exports, which is where sellers most often misplace it.
Does the foreign tax credit stop me being taxed twice?
It helps, and it is not a guarantee. Section 126 of the Income Tax Act gives a credit for foreign income or profits tax actually paid, set against the Canadian tax otherwise payable on that same income. It works well when the two systems are looking at the same income in the same period and measuring it in broadly the same way. It works much less well when they are not: different characterisations, different timing, income a state taxes that the federal system does not, or foreign tax paid on something Canada does not treat as income at all. That is where relief runs out and the credit leaves a residue.
Do I have a permanent establishment in the United States?
It has to be determined on your own facts; anybody handing you a one-line answer has not looked at them. A permanent establishment is, in broad terms, a fixed place of business through which the business of an enterprise is wholly or partly carried on, and Article V of the Canada–United States tax treaty sets out what counts and what is carved out of it. Whether you have one is a facts-and-circumstances question: what is in the United States, who is there, what they do and under whose direction. Separately: US state income tax is not the same subject as US sales-tax registration, and a state can reach into a business’s income on a basis unrelated to whether it collects that state’s sales tax.
What records does CRA expect, and what if none of this has ever been reported?
Six years is the retention period section 230 of the Income Tax Act sets for books and records, and on a cross-border seller the set runs well past bank statements: the platform payout reports, the payment-processor statements, the contract with every non-resident you pay together with evidence of where they did the work, shipping evidence on export orders, inventory counts by location, and the intercompany invoices between your own companies. Payout reports matter most, because platforms do not keep them indefinitely and they cannot be reconstructed later. Where a return, or the records supporting it, is not produced, subsection 152(7) of the Income Tax Act permits CRA to assess whatever amount it thinks appropriate. And if none of this has ever been reported, the move is to go first: Form RC199 for a Voluntary Disclosures Program application, Form RC4288 where relief is the right ask.

Related Industries We Serve

Accountant for Importers

  • Goods brought in for resale
  • Supplier currency and landed cost
  • T2 filing and monthly bookkeeping

Accountant for Distributors

  • Territory rights and dealer supply
  • Manufacturer allowances and rebates
  • Corporate tax planning and the T2

Accountant for Direct-to-Consumer Brands

  • Storefront revenue and returns
  • Customer acquisition cost
  • Year-end statements and the T2

Accountant for Wholesale Businesses

  • Volume pricing and trade terms
  • Stock counts and write-downs
  • T2 filing and compiled statements

Cross-Border E-Commerce Accounting & Tax Done Right.

T2 filing with revenue split by destination and stock valued under subsection 10(1) wherever it sits; Regulation 105 withholding applied where a non-resident renders services in Canada and correctly not applied where the work was done abroad; Part XIII tax and NR4 reporting handled as the separate regime they are; Form T1135, Form T1134 and Form T106 filed where the structure triggers them, with section 247 documentation behind your intercompany pricing; the section 261 functional currency election on Form T1296 where it suits you; the section 126 foreign tax credit calculated rather than assumed; and 13% on Canadian-delivered orders with exports reviewed against Part V of Schedule VI. AFFORDABLE flat fees instead of hourly billing. Licensed CPA Ontario. 1300+ five-star reviews. 30-Day Money-Back Guarantee.



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