Nakul Kohli, Jiani Qian, "Canadian Residents Earning Income Through Non-Resident US LLCs", Canadian Tax Focus, Vol. 12, No. 1, February 2022, p. 10

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 4

Non-application of US Treaty reduction where Canadians receive dividends from a Canco through an LLC (p. 10)

  • An LLC with US and Canadian...

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Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1)

Canadian residents generally are better off investing in a portfolio that may include Canadian companies through a partnership rather than an LLC...

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