Cross-Border Structuring for a Canadian Small Business Expanding into the US

A Cana­di­an small busi­ness own­er want­ed to begin sell­ing into the Unit­ed States but was con­cerned about trig­ger­ing US cor­po­rate tax expo­sure and dou­ble tax­a­tion on the same prof­its. We reviewed the com­pa­ny’s pro­posed US activ­i­ties under the Cana­da-US tax treaty, advised on the appro­pri­ate enti­ty struc­ture, and pre­pared the US fed­er­al fil­ings required once the busi­ness began gen­er­at­ing effec­tive­ly con­nect­ed income. Out­come: the client expand­ed into the US mar­ket with a com­pli­ant struc­ture and no unex­pect­ed US tax expo­sure.

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