A popular hybrid entity for U.S. residents seeking to invest in Canada has been the unlimited liability company (“ULC”). The corporate law of certain Canadian provinces (i.e. Nova Scotia, Alberta and British Columbia) allows for the incorporation of ULCs, which have proliferated over the years largely because of the fact that they qualify for "check-the-box" treatment under the Treasury Regulations to the U.S. Internal Revenue Code. This treatment generally permits U.S. resident investors to access a combination of Canadian and U.S. tax benefits that are otherwise unavailable in respect of Canadian investments made through other corporate entities.

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