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.