Canadian owned US business

[Ronden]

Hi. I am currently expanding my portfolio of e-commerce websites to market to the USA. In doing so, I am in the process of developing relationships with US wholesale suppliers who, for the most part, require a USA business entity to deal with and a state resellers permit or sales tax id.

I am a Canadian citizen and resident. I have a USA mailing address in Washington state and I am contemplating creating a Wyoming LLC through which I will run my online business.

I am confused as to the effect of Protocol 5 of the treaty with respect to how I ( and my LLC ) will be taxed and by whom?

I think that Protocol 5 says that CRA will view the LLC as a pass through entity. I assume that I will file a 1040NR and pay tax to the IRS.

Any help would be greatly appreciated, even if it is only to point me in the direction of a competent advisor who can assist in establishing this business.

Thank you...