The following is a follow up to my response to a question regarding
the Candian tax treatment of owning an interest in a U.S. LLC.
Vern
I'm not an expert but I do have some experience -- I had a US LLC with
Canadian members and have a US LLC that does some business in Canada.
In 2007, Canada did not recognize the look-through aspect of the LLC
so they treated an LLC (regardless of an election to be treated as a
partnership) as a corporation for tax purposes. There are proposed
rule changes that derive from that tax treaty, but they had not taken
effect in 2007. I believe I was told by my Canadian accountants that
the rule changes likely -- but not definitely -- will take effect in
2008. Maybe some of your other readers can correct or confirm.
(Name Withheld)