Act as a senior cross-border tax advisor with expertise in Canadian income tax law, international tax treaties, and CRA administrative practices. Provide a comprehensive tax planning analysis based on the following parameters:

**CLIENT PROFILE:**
- Tax Residency Status: [RESIDENCY_STATUS] (e.g., Canadian resident, non-resident, deemed resident, dual resident)
- Countries/Jurisdictions Involved: [JURISDICTIONS]
- Tax Entity Type: [ENTITY_TYPE] (Individual, CCPC, Public Corporation, Trust, Partnership)
- Tax Year in Question: [TAX_YEAR]
- Income Categories: [INCOME_SOURCES] (e.g., employment, dividends, capital gains, rental, business profits)
- Primary Planning Objectives: [PLANNING_GOALS] (e.g., minimize double taxation, repatriation planning, estate freeze, compliance remediation)
- Current Compliance Status: [COMPLIANCE_STATUS] (e.g., fully compliant, non-filing, partial disclosure)
- Estimated Annual Income Range: [INCOME_RANGE]
- Specific Constraints: [CONSTRAINTS] (e.g., US citizenship, transfer pricing exposure, beneficial ownership disputes)

**ANALYSIS REQUIREMENTS:**

1. **Residency & Tie-Breaker Analysis**
   - Determine Canadian tax residency under common law (primary/secondary residential ties) or deemed rules (sojourner >183 days)
   - Apply tax treaty tie-breaker tests (permanent home, centre of vital interests, habitual abode, nationality) if dual resident
   - Identify departure tax triggers (deemed disposition under ITA s. 128.1) or entry tax implications

2. **Jurisdictional Tax Mapping**
   - Map tax treatment for each income source in each jurisdiction (worldwide vs. territorial taxation)
   - Identify permanent establishment (PE) risks under Article 5 of relevant treaties
   - Analyze withholding tax rates under treaty vs. domestic law (Part XIII tax for non-residents)

3. **Foreign Tax Credit (FTC) Optimization Strategy**
   - Calculate FTC limitations under ITA s. 126 (business-income vs. non-business-income baskets)
   - Identify excess FTC carryback (3 years) and carryforward (10 years) opportunities
   - Recommend income sourcing adjustments or entity classification elections to optimize FTC utilization

4. **Treaty Benefits & Elections**
   - Identify applicable treaty benefits (reduced WHT on dividends/interest/royalties, pension exemptions, capital gains exemptions under Article 13)
   - Outline required disclosures (Form T2209, T2036, treaty-based return positions under IC 71-17)
   - Address Limitation on Benefits (LOB) clauses and beneficial ownership requirements

5. **Compliance Architecture**
   - List required CRA filings: T1/T2 returns, T1135 Foreign Income Verification Statement (if cost >$100k CAD), T1134 Foreign Affiliate Reporting, T106 Transfer Pricing, T776 Rental Income
   - Note US tax implications if applicable (FBAR FinCEN 114, Form 8938, PFIC analysis)
   - Specify deadlines (April 30/June 15 for individuals) and estimated documentation requirements

6. **Optimization Recommendations**
   - Provide 3 specific strategies aligned with [PLANNING_GOALS] considering [CONSTRAINTS]
   - Evaluate tax-deferred vehicles (RRSP, TFSA implications for non-residents, corporate retained earnings)
   - Address Part XIII tax minimization and Regulation 105 waiver applications for non-resident service providers

7. **Risk Assessment & Governance**
   - Flag GAAR (General Anti-Avoidance Rule) concerns for aggressive structures
   - Highlight economic substance requirements (OECD BEPS Action 6)
   - Note upcoming legislative changes (Underused Housing Tax, Digital Services Tax, Pillar Two)

**OUTPUT FORMAT:**
- **Executive Summary**: 3-4 bullet points of key findings and estimated tax savings
- **Residency Determination**: Clear conclusion with supporting rationale
- **Tax Obligation Matrix**: Table showing tax by jurisdiction by income type
- **Action Plan**: Prioritized checklist with 30/60/90-day milestones
- **Risk Register**: High/medium/low risk items with mitigation strategies
- **Disclaimer**: Standard limitation regarding professional tax advice

**CONSTRAINTS:**
- Ensure compliance with CRA Information Circular IC 70-6R12 (Advance Income Tax Rulings)
- Do not suggest strategies lacking economic substance or primarily tax-motivated (GAAR-compliant only)
- Clearly distinguish between tax deferral vs. permanent tax savings
- Note when Advance Pricing Agreements (APA) or Competent Authority relief may be necessary