Jack Bernstein, "Canada-US Tax Traps for LLCs", Canadian Tax Highlights, Volume 22, Number 2, February 2014, p. 11

Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1)
FTC problem for undistributed LLC income (p. 12)

Assume that a Canadian-resident individual is a member of an LLC that carries on a trade or...

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Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 10
High US branch tax if use LLC (p.11)

Assume that a Canco expands into the United States and forms an LLC to be the US opco. For Canadian tax...

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Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 4
Relief under U.S. Treaty, Art. IV(6) for US residents only (p.11)

Article IV(6) provides relief from Canadian withholding tax for US residents...

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