This term is used by professionals in Canada as a way of describing
consulting and compliance services which require knowledge of both Canada
and U.S. tax law and procedures.
U.S. entity which is treated as a partnership for U.S. tax purposes but
which can provide limited liability for its members. Generally
speaking, Canada does not treat an LLC as a partnership.
U.S. corporation that makes a timely filed election to be treated as a
flow through entity for U.S. tax purposes. Generally speaking, Canada
does not accept this treatment as a flow through entity for Canadian tax
purposes.
This is a newsletter distributed by our firm to other professional
accounting and legal firms throughout Canada and the United States.
This newsletters purpose is to raise awareness of U.S. and cross-border
issues and is not meant as a comprehensive source of
information.