Good video..! I'm a Canadian in a high risk and legal business that is not easily insurable. I'm looking to open a Wyoming LLC for asset protection as a separate corporation from my Canadian high risk corporation. I am just looking at the Wyoming LLC to store liquid cash assets in the unfortunate event if the Canadian corporation ever gets sued. I know this is not 100% asset protection but much better than what we have in place now - nothing. That being said if we move over (Wire) significant assets to the Wyoming LLC and a US based major bank we obviously don't want the cash to sit there but would rather have it invested in the stock market or money market or term deposit - to get some interest or capital gains on the money. We were told that any income from the Wyoming LLC may be subject to 30% or 35% withholding tax. But that was just a blanket statement from that person (they specialize in real estate investments which we're not interested in). Would investment income be subject to this withholding tax by the IRS? That person suggested we use a Wyoming LLP instead of a LLC, They said the LLP would be under the Canada USA tax treaty to allow recovery or credit of the withholding tax. But I prefer the LLC structure as its provides more of what we want - more protection. I guess the question at the end of the day is: Can we wire money to a Wyoming LLC with a EIN, US bank account, and gain investment interest/capital gains without withholding tax in the USA? Would this be determined by the IRS as effectively connected income? Thanks in advance!
Hi Allan do you have a video like this but on company selling online like on amazon fba? I just open a Incorporation in Quebec Canada and was woundering if I made the good choice? and if I should get the EIN and fill the IRS yearly tax to claime my exemption?
Hi Alexandre, thank you for your question. I understand that you incorporated a company in Quebec and are selling products to US customers via Amazon.com. So long as your company does not have a permanent establishment in the US, it does not have to pay US profits tax on sales made to US customers. Note that a warehouse (e.g. Amazon fulfillment center) is not treated as a permanent establishment. To claim an exemption from US profits tax, your company will have to file a US corporate tax return (1120F) and Treaty Statement (8833). It will also need a US EIN. I can help you with tax filings and obtaining a US EIN.
What if I use the LLC earnings as collateral for a line of credit/loan? Would that money still be double taxed? It shouldn't right, because it's a loan.
What if I own a corporation as an independent contractor and go to work in the USA as a contractor? What would be best? You can assume an income of 100-200K.
Was this posted after the new Tax Treaty came about? If so does this still stand true, and what is the difference between a U.S LP, a U.S LLP? and an LLLP? Thanks man great video!
Why wouldn't you just take put the profits from the US LLC as a management fee back to Canada? Wouldn't that be simple avoid the double taxation. So if you made $20,000 on $200,000 as an example in the US LLC take the $20,000 profit out as a management fee and pay tax on the $20,000 profit in Canada to the CRA. Therefore the US LLC effectively made no profit would be due to the IRS. With this not be possible?
I’m located in the us and my brother in Canada i wanted to get a LLC for our rental. Can I open up the LLC here in the us and have him as 50% Owner? So partnership
Hi. If I don't use Single member LLC for USA investments, but rather for Canadian business only (I'm assuming CRA only) would that be a good choice for a noncorporate solo proprietor in case if I'd like to incorporate? Ot should I just create a corporation and be my own corporation employee? Thanks
Is there a difference between the US LP and the US LLLP? Also does this apply to E-commerce businesses that have been registered in the U.S. by Canadian residents?
Hi Sankeethan, e-commerce businesses can operate through a US LP as well. A US LLC and US LLLP will result in double taxation for Canadians, because both of these structures are treated as foreign corporations by the CRA. To avoid double taxation, structure your business through a US LP or through a US C-corporation.
Thank you for your insightful tips, your content and tips are amazing! I have one additional question; what is the difference between a US LP and a US C-corporation? I’ve heard that US C-corporations pay double tax as an entity and through dividends.
A US C-corp is a separate legal entity that pays corporate income tax. If not structured properly, you will be double taxed. A US LP is a limited partnership. A partnership does not pay tax. Instead, the limited partners pay tax on their share of the profits from the US LP.
What's the advantages of a US limited partnership vs purchasing real estate in the USA under my own name? I have multiple properties currently, should they be a US LP?
you are only talking about real estate property here. I'm interested in registering a service business under llc and not real estate property, does this have the same double taxation results?
Good video..! I'm a Canadian in a high risk and legal business that is not easily insurable. I'm looking to open a Wyoming LLC for asset protection as a separate corporation from my Canadian high risk corporation. I am just looking at the Wyoming LLC to store liquid cash assets in the unfortunate event if the Canadian corporation ever gets sued. I know this is not 100% asset protection but much better than what we have in place now - nothing.
That being said if we move over (Wire) significant assets to the Wyoming LLC and a US based major bank we obviously don't want the cash to sit there but would rather have it invested in the stock market or money market or term deposit - to get some interest or capital gains on the money.
We were told that any income from the Wyoming LLC may be subject to 30% or 35% withholding tax. But that was just a blanket statement from that person (they specialize in real estate investments which we're not interested in). Would investment income be subject to this withholding tax by the IRS?
That person suggested we use a Wyoming LLP instead of a LLC, They said the LLP would be under the Canada USA tax treaty to allow recovery or credit of the withholding tax. But I prefer the LLC structure as its provides more of what we want - more protection.
I guess the question at the end of the day is: Can we wire money to a Wyoming LLC with a EIN, US bank account, and gain investment interest/capital gains without withholding tax in the USA?
Would this be determined by the IRS as effectively connected income?
Thanks in advance!
This was a fantastic video. Wow. Definitely subscribing just for how well made this was.
Thank you very much for super informative video!It was very helpful
How are Canadians taxed for having C Corp?
Once again, great video. Thanks Allan.
If I choose a state that has no corporate or individual tax, doesn't an LLC still make sense?
Hi Allan do you have a video like this but on company selling online like on amazon fba? I just open a Incorporation in Quebec Canada and was woundering if I made the good choice? and if I should get the EIN and fill the IRS yearly tax to claime my exemption?
Hi Alexandre, thank you for your question. I understand that you incorporated a company in Quebec and are selling products to US customers via Amazon.com. So long as your company does not have a permanent establishment in the US, it does not have to pay US profits tax on sales made to US customers. Note that a warehouse (e.g. Amazon fulfillment center) is not treated as a permanent establishment.
To claim an exemption from US profits tax, your company will have to file a US corporate tax return (1120F) and Treaty Statement (8833). It will also need a US EIN. I can help you with tax filings and obtaining a US EIN.
What if I use the LLC earnings as collateral for a line of credit/loan? Would that money still be double taxed? It shouldn't right, because it's a loan.
What if I own a corporation as an independent contractor and go to work in the USA as a contractor? What would be best? You can assume an income of 100-200K.
Was this posted after the new Tax Treaty came about? If so does this still stand true, and what is the difference between a U.S LP, a U.S LLP? and an LLLP? Thanks man great video!
Why wouldn't you just take put the profits from the US LLC as a management fee back to Canada? Wouldn't that be simple avoid the double taxation. So if you made $20,000 on $200,000 as an example in the US LLC take the $20,000 profit out as a management fee and pay tax on the $20,000 profit in Canada to the CRA. Therefore the US LLC effectively made no profit would be due to the IRS. With this not be possible?
Hi Allen, great videos. Do you have more information about USLPs?
I'm thinking of naming my painting business LLC (Canada only) vs Inc or LTD.
Suggestions?
Should I have a Canadian Corp that owns a C Corp to trade US stocks?
I’m located in the us and my brother in Canada i wanted to get a LLC for our rental. Can I open up the LLC here in the us and have him as 50% Owner? So partnership
Hi. If I don't use Single member LLC for USA investments, but rather for Canadian business only (I'm assuming CRA only) would that be a good choice for a noncorporate solo proprietor in case if I'd like to incorporate? Ot should I just create a corporation and be my own corporation employee? Thanks
Hi Kirill,
LLCs are not available in Canada. Incorporate a Canadian company instead.
@@AllanMadanCA oh ok...
Is there a difference between the US LP and the US LLLP? Also does this apply to E-commerce businesses that have been registered in the U.S. by Canadian residents?
Hi Sankeethan, e-commerce businesses can operate through a US LP as well. A US LLC and US LLLP will result in double taxation for Canadians, because both of these structures are treated as foreign corporations by the CRA. To avoid double taxation, structure your business through a US LP or through a US C-corporation.
Thank you for your insightful tips, your content and tips are amazing! I have one additional question; what is the difference between a US LP and a US C-corporation? I’ve heard that US C-corporations pay double tax as an entity and through dividends.
A US C-corp is a separate legal entity that pays corporate income tax. If not structured properly, you will be double taxed.
A US LP is a limited partnership. A partnership does not pay tax. Instead, the limited partners pay tax on their share of the profits from the US LP.
@@AllanMadanCA does a US LP act like a corporation? Can it hold profits? Can you please elaborate on the taxation rate for a USLP vs a Corporation?
Also does a US LP limit the amount of personal risk as a corporation does?
What's the advantages of a US limited partnership vs purchasing real estate in the USA under my own name? I have multiple properties currently, should they be a US LP?
Hi Akash, a US LP will provide you with liability protection so that your personal assets are not at risk in the event of a lawsuit.
you are only talking about real estate property here. I'm interested in registering a service business under llc and not real estate property, does this have the same double taxation results?
Yes, a service business held through a LLC by a Canadian resident will still result in double taxation.
Form a corp forget the llc got it