The Resource 11 traps for U.S. LLCs investing in Canada

11 traps for U.S. LLCs investing in Canada

Label
11 traps for U.S. LLCs investing in Canada
Title
11 traps for U.S. LLCs investing in Canada
Creator
Subject
Language
eng
Summary
Even though the fifth protocol to the Canada-U.S. tax treaty added some relief for U.S. residents using limited liability companies to invest in Canada, there continue to be Canadian or U.S. traps for the unwary. This article provides examples of 11 such traps. The problems stem from the fact that Canada regards an LLC as a company not eligible for treaty benefits unless it elects to be taxed in the United States as a corporation. In the United States, under the default rule, an LLC is either disregarded if owned by a single member or treated as a partnership if there are several members
Citation source
In: Tax notes international. - Falls Church. - Vol. 74 (2014),
http://library.link/vocab/creatorName
Bernstein, J
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • limited liability company
  • tax treaty
Label
11 traps for U.S. LLCs investing in Canada
Instantiates
Publication
Label
11 traps for U.S. LLCs investing in Canada
Publication

Library Locations

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      52.37366609999999 4.9336932
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