Serbinski Accounting Firms

hmm what about an LLC (partnership) with PE outside of canada? Wouldnt there be no need for tax credit given that the canadian partner would not pay income tax in the US?

Or is there an issue generated by the hybrid status?

I guess the permanent establishment would be in Canada, but I guess it matters more to be able to show that you dont have a PE in the US?



In terms of avoiding US taxation for an LLC taxed as a partnership with no permanent establishment in the US, is the fact that a US LLC is a hybrid entity ...

Or... would an LLC with no permanent establishment in the US, and that is taxed as a corp avoid paying corporate tax?

Thanks for the reply.

Wouldn't it be smarter to not be treated as a partnership for tax purposes, and given that we don't have a permanent establishment in the US, not pay income tax there?

Because if I check the box and get treated as a corp for tax purposes we would have to pay corporate tax ...

Hi,

I am a Canadian resident and am building an online store that would be selling to US residents.

I have a partner in this venture who is from South Africa.

We are considering setting up an LLC taxed as a partnership.


My understanding is that we will not have a permanent establishment since ...

Maybe Ill simplify my questions...


If as a Canadian resident I were be a partner in a US LLC...


Is there a way to avoid double taxation? Does it work if I make sure that any profit my LLC makes in a given year is transferred to me in the same year?

Then I can use whatever taxes I pay in the US ...

Hello,

I am a canadian permanent resident.

My business partner (non US, non canadian) and I are working on building an online store that would work with US dropshippers and sell to the US market.

In order to run this, we are considering setting up our business in the US.

An LLC would seem like ...