Submitted by inclawyers on Thu, 12/04/2007 - 11:08am
This article is left here for historical reference. On the whole, amendments to the US/Canada Tax Treaty that came into effect in early 2010 generally make Canadian ULCs undesirable. That said, as of October 2012, we still have some demand for these vehicles, based on current advice. Be sure that you've got good income tax advisers on each side of the US/Canada border if you're going to use a Canadian ULC in your business structure.
Good news for US businesses or US residents looking to do business in Canada!