“Implications of Restructuring a Canadian Unlimited Liability Company: Fallout from the Fifth Protocol,”
Canadian Tax Journal, 2009, Vo. 57, No. 1., p. 171-92
Date:
May 7 2009
As of January 1, 2010, the fifth protocol will eliminate many of the benefits currently available under the tax treaty between Canada and the United States regarding amounts paid by a Canadian unlimited liability company (ULC) to a U.S. resident. The loss of tax benefits may significantly influence the continued viability of ULCs in cross-border U.S. tax planning. The coauthors of this article, Matthew Peters and Elizabeth H. Peters, discuss the historical significance of ULC and the benefits and risks of certain restructuring alternatives from both Canadian and U.S. tax perspectives.
For further information, please contact Matthew Peters.