Canadian tax treatment of U.S. LLC. (limited liability company): An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on November 1, 1996. The length of the article is 536 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: Revenue Canada has ruled that US limited liability companies (LLCs) will not be eligible for treaty benefits, unlike S corporations. Revenue Canada will treat LLCs like corporations because treaty relief is available only to entities that are liable to tax in their home country and LLCs are not taxable by design. Canadian officials characterize S corporations as entities that would be taxable but for the S election. Since treaty relief is not available, LLCs can be subject to Canada's branch tax without exemption and to its withholding requirements.

Citation Details
Title: Canadian tax treatment of U.S. LLC. (limited liability company)
Author: Peter N. Corcoran
Publication:The Tax Adviser (Magazine/Journal)
Date: November 1, 1996
Publisher: American Institute of CPA's
Volume: 27 Issue: n11 Page: 661(1)

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