LLCs owned by US-resident individuals are not entitled to the 5% branch profits rate
10 July 2013 - 9:52am
Email this ContentCRA also has published its response at the 2010 annual CTF conference indicating that the branch tax reduction under X(6) of the Canada-US Tax Convention is not available to an LLC that is wholly-owned by US-resident individuals.
Neal Armstrong. Summary of 28 November 2010 Annual CTF Round Table, Q. 17, 2010-0386391C6 under Treaties – Art. 10 (see also summary of 23 October 2012 T.I. 2012-0440101E5).