Discussion:U.S. Citizen purchasing Candian publicly traded stock wants to hold the stock in a U.S. LLC.
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| Revision as of 01:10, 11 September 2007 Smktax (Talk | contribs) (LK, Would the Ca) ← Previous diff |
Revision as of 22:30, 20 September 2007 LKfromCANADA (Talk | contribs) (Sorry, been away) Next diff → |
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| {{ForumReplyPost|UserID=Smktax|Date=11 September 2007|Text=LK, Would the Canadian result be any different if the LLC elected to be treated as an S corp?}} | {{ForumReplyPost|UserID=Smktax|Date=11 September 2007|Text=LK, Would the Canadian result be any different if the LLC elected to be treated as an S corp?}} | ||
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| + | {{ForumReplyPost|UserID=LKfromCANADA|Date=20 September 2007|Text=Sorry, been away a few days. | ||
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| + | No, Canada considers an LLC to be a corporation whether or not an election is made}} | ||
Revision as of 22:30, 20 September 2007
Discussion Forum Index --> Tax Questions --> U.S. Citizen purchasing Candian publicly traded stock wants to hold the stock in a U.S. LLC.
| 2 September 2007 | |
| Does anyone see a problem from a Canadian standpoint if a U.S.citizen holds their Canadian stock through an LLC? Would you lose the benefit of the lower treaty withholding rate on the dividends? Any advice would be greatly appreciated. Thank you! | |
| 3 September 2007 | |
| From a CDN standpoint? Sorry, no can say, but from the US standpoint the treaty is double sided. If the US has a treaty on the income, then CDA also abides by the treaty. However, the source of the income is taxable first, so CDA could essentially tax the income first and then the US imparts the treaty benefits.
Is this public traded stock or closely held stock? Is the US citizen through the stock ownership actually operating a business in the US or is it only investment activity? Best bet for CDN answers is to speak to a CDN chartered accountant.... | |
| 7 September 2007 | |
| Thanks Sandy, I appreciate your time and knowledge-the stock is publicly traded and the LLC is purely a holding mechanism for the stock-investment only. | |
LKfromCANADA (talk|edits) said: | 10 September 2007 |
| Canada views an LLC as a regular C corporation. You would still get the reduced withholding on dividends. | |
| 11 September 2007 | |
| LK, Would the Canadian result be any different if the LLC elected to be treated as an S corp? | |
LKfromCANADA (talk|edits) said: | 20 September 2007 |
| Sorry, been away a few days.
No, Canada considers an LLC to be a corporation whether or not an election is made | |
