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Cross-border business and corporations

Canadians with US LLCs and US persons with Canadian corporations: Form 5471, the CFC rules, FAPI, transfer pricing, nexus, choosing a structure, and contractors working across the border.

36 guides, each written by a CPA licensed in the US and Canada.

Cross-Border

Can a Canadian Own a Business in the US? The Tax Side

Yes. A Canadian can own a US corporation, LLC or branch. The vehicle sets your tax: a C corporation usually beats an LLC for a Canadian resident, and owning isn't a work permit.

Oct 24, 2026
Cross-Border

Can I make a check-the-box election on my Canadian corporation before I move to the US?

Usually not. Canadian Corporations and Companies are treated as corporations for US tax, so Form 8832 is closed to them.

Aug 7, 2026
Cross-Border

Canadian CCPC with a US Shareholder: How Integration Breaks and What to Do About It

Canada's corporate integration system is designed so that income earned through a CCPC is taxed at roughly the same rate as income earned personally.

Sep 4, 2026
Cross-Border

Canadian Starting a Business in the US: The Tax Guide

A Canadian starting or buying a business in the US faces a set of decisions that are different from those facing a US domestic entrepreneur.

Aug 30, 2026
Canadian Tax

CCPC: What Is a Canadian-Controlled Private Corporation and Why It Matters

CCPC status unlocks the small business deduction (9% on the first $500,000), the lifetime capital gains exemption, and refundable tax on investment income.

Aug 24, 2026
Cross-Border

Contractor vs Employee Classification Cross-Border: Canada-US

Canada and the US use different tests to classify workers. Misclassification across the border creates liability in both countries.

Aug 30, 2026
Cross-Border

Cross-Border Business Structures: Comparing Options for Operating in Both Canada and the US

A cross-border business must choose between an LLC, a corporation, and a branch. Each produces different tax consequences in Canada and the US.

Sep 4, 2026
Cross-Border

Do I Have to File Form 5471 for My Canadian Corporation?

Yes, if you're a US person who controls it or owns 10% of it while US owners hold over 50%. A decision table by situation, what missing it costs, and how to catch up.

Jul 29, 2026
Cross-Border

Do I need to file a T1134 for my US company?

Yes if you're resident in Canada and a US corporation is your foreign affiliate: 1% yourself, 10% across related persons, 10 months after year end.

Aug 7, 2026
Cross-Border

Do I Send a 1099 to a Canadian Contractor?

US businesses do not issue a 1099 to Canadian contractors who provide a W-8BEN. The W-8BEN claims the treaty exemption and eliminates US withholding.

Aug 24, 2026
Cross-Border

EIN Number in Canada: The BN Equivalent and How to Apply

Canada's version of an EIN is the CRA business number (BN). A Canadian company that needs a US EIN files Form SS-4 by phone, fax or mail, pays no fee, and can get it on the call.

Aug 24, 2026
Cross-Border

Form 1120-F for a Canadian Corporation: When to File

A Canadian corporation files Form 1120-F for any year it runs a US trade or business, even one the treaty exempts. File on time or lose deductions. Dates and forms here.

Oct 24, 2026
Cross-Border

Form 5471 Filing Requirements for a Canadian Corporation

A US person who controls or owns 10% of a Canadian corporation generally files Form 5471 with their return. The five categories, schedules, $10,000 penalty and open statute.

Sep 4, 2026
Cross-Border

GILTI Is Now Net CFC Tested Income: Canadian Corporations

From 2026, GILTI is net CFC tested income: no QBAI carve-out, a 40% deduction and a 90% credit. A CCPC at the small business rate usually fails the high-tax test.

Aug 7, 2026
Cross-Border

I'm a Canadian Freelancer with US Clients. Do I Need a W-8BEN?

Without a W-8BEN, your US client must withhold 30% of what they pay you. With one claiming the treaty rate, withholding drops to 0%.

Aug 21, 2026
Cross-Border

Incorporating a Business Cross-Border: Canada vs US

A Canadian resident who forms a US LLC is taxed on the LLC's income in Canada at personal rates, gets no corporate deferral, and may owe US tax too.

Aug 30, 2026
Cross-Border

Is a US LLC a tax trap for Canadians, and how do I fix it?

Usually yes, because the two countries disagree about what your LLC is. The IRS ignores it and taxes you personally as the profit is earned.

Jul 23, 2026
Canadian Tax

LLC in Canada: What Canada Uses Instead of an LLC

Canada has no LLC. You choose a sole proprietorship, partnership or corporation, or a ULC in Alberta, BC or Nova Scotia. How each is taxed in Canada and the US.

Oct 24, 2026
Cross-Border

My Spouse Owns a Canadian Corporation. Do I File Form 5471?

If your spouse owns 10% or more of a Canadian corporation, IRC 958(b) attributes those shares to you, making it a CFC. Covers treaty provisions, foreign.

Aug 21, 2026
Cross-Border

RDTOH and US shareholders of Canadian corporations

How Canada's refundable dividend tax on hand system interacts with US tax rules for Americans owning CCPCs, including CFC, GILTI.

Aug 27, 2026
Cross-Border

Regulation 105: I'm a US Contractor Providing Services in Canada

Canadian payers must withhold 15% of gross payments to US contractors under Regulation 105. A treaty-based waiver can reduce or eliminate the withholding.

Aug 21, 2026
Cross-Border

Section 199A QBI Deduction for Cross-Border Filers

How the qualified business income deduction works when you have a Canadian business, foreign income, or cross-border rental.

Aug 30, 2026
Cross-Border

Section 85 Rollover: Cross-Border Tax Implications

Section 85 of the Income Tax Act lets a Canadian taxpayer transfer property to a Canadian corporation on a tax-deferred basis.

Aug 30, 2026
Cross-Border

Section 962 Election: How Individual CFC Shareholders Get the Corporate Tax Rate

A Section 962 election lets a US individual pay the 21% corporate rate on CFC income and claim indirect foreign tax credits for Canadian corporate tax.

Aug 24, 2026
Cross-Border

Self-Employed and Cross-Border: Canada-US Tax for Freelancers and Sole Proprietors

A Canadian freelancer working from home for US clients usually owes Canadian tax and CPP, not US tax. How the treaty, the W-8BEN and the totalization agreement apply.

Aug 30, 2026
Cross-Border

Selling a Cross-Border Business: Tax on the Sale When Owner and Company Span Canada and the US

A share sale, asset sale, or earn-out each produce different tax results in Canada and the US. Treaty credits limit but do not eliminate double tax.

Sep 4, 2026
Cross-Border

Subpart F Income: What It Is, What Triggers It, and How It Hits Canadian Corporations

Subpart F taxes passive and mobile income of a CFC directly to US shareholders, even without a distribution. interest. Covers treaty provisions, foreign.

Aug 24, 2026
Cross-Border

The US LLC Tax Trap for Canadians: Why a Disregarded Entity Creates Double Taxation

A Canadian who owns a single-member US LLC can face double taxation, because Canada treats the LLC as a corporation while the US taxes its income on the owner's return.

Sep 4, 2026
Cross-Border

Transfer Pricing Between Canada and US Related Companies: What the Rules Require

When related companies in Canada and the US transact with each other, both countries require arm's-length pricing. Covers treaty provisions, foreign tax.

Sep 4, 2026
Cross-Border

Transfer Pricing Cross-Border: Getting Related-Party Prices Right Between Canada and the US

If your Canadian and US companies do business with each other, the prices you charge between them must be arm's length. Covers treaty provisions, foreign.

Aug 30, 2026
Cross-Border

Transfer Pricing for Small Cross-Border Businesses: How the IRS and CRA Police Intercompany Transactions

A small business operating in both Canada and the US through related entities must price intercompany transactions at arm's length.

Sep 4, 2026
Cross-Border

US S-Corp or Partnership Income as a Canadian Resident

US flow-through entities (S-Corps and partnerships) pass their income to the owners' personal returns. For a US-resident owner.

Aug 21, 2026
Cross-Border

US Subsidiary vs US Branch for a Canadian Company: Tax, Liability, and Filing Differences

A Canadian company expanding to the US chooses between a subsidiary and a branch. The tax, liability, and loss-utilization differences are significant.

Sep 4, 2026
Cross-Border

W-8BEN vs W-8BEN-E vs W-9: Which Form a Canadian Signs

Individuals sign the W-8BEN, Canadian corporations sign the W-8BEN-E, and only US persons sign a W-9. What each form claims and what a wrong form costs.

Oct 24, 2026
Cross-Border

W-8BEN-E for a Canadian Corporation: Line-by-Line Guide

A Canadian corporation gives Form W-8BEN-E to each US payer to claim treaty rates. Line by line: Part I, active NFFE status, the Part III treaty claim and the LOB test.

Aug 30, 2026
Cross-Border

When Does a Canadian Business Create US Tax Nexus? Physical Presence, ECI, and the Treaty Shield

A Canadian business creates US tax nexus when it earns income that is effectively connected with a US trade or business.

Sep 4, 2026

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