In TD Securities (USA) LLC v. The Queen, Canada’s Tax Court considered for the first time whether a fiscally transparent U.S. LLC (TD LLC) was a “resident” of the U.S. and therefore entitled to the 5% reduced rate of Canadian branch profits tax under the Canada-U.S. Income Tax Convention (“Treaty”) (…)

type Fiscally Transparent U.S. LLC Entitled to Canada-U.S. Treaty Benefits