I received some bad advice and purchased shares in a US LLC within a Cdn resident Corporation. My Corp & I are both Cdn resident with no U.S. permanent residence.
I "now" think I understand the problem with the double taxation issue.
I believe I will be taxed on the dividends paid to my Cdn Corp as well as being taxes in the US on the income with no ability to claim a foreign tax credit. Am I correct? If so, are there any solutions at this time. There is quite a large gain accumulated in the investment so a transfer to me is not feasible.
Can I pay reasonable managment fees to myself (Cdn) and have them be deductible on the US 1120-F filing? Would I have to file a US individual return on these fees if I reside in Canada and earn the fees here?
T
LLC PROBLEMS
Moderator: Mark T Serbinski CA CPA