Canada-US Tax Treaty and LLC Income: What Changes in 2026
Section 899 was dropped in July 2025, but the Canada-US treaty still has gaps for LLCs. What the treaty covers, what it misses, and why Section 899 matters.
CRA and US LLCs: The Tax Classification Trap Canadians Face
The CRA treats US LLCs as corporations. The IRS treats them as pass-through. This mismatch creates effective tax rates of 50-75% for Canadian founders.
HMRC and US LLCs: The Opaque Entity Tax Trap (2026)
From April 2025, HMRC treats US LLCs as opaque entities. UK residents now face potential double taxation that the US-UK treaty may not resolve.
India Tax Residency and US LLC: What the Treaty Covers
India uses 182 days (not 183). Residents face worldwide taxation. The India-US DTAA has gaps that catch LLC owners. Here is what the treaty actually says.
Receita Federal and US LLCs: No Tax Treaty, No Safety Net
Brazil has no US tax treaty. Carnê-Leão is due monthly. BACEN reporting applies above $100K. The compliance reality for Brazilian LLC owners.
Turkish Tax Rules and US Banking for LLC Owners (2026)
GIB taxes worldwide income. The Lira makes USD revenue essential. The Turkey-US treaty covers business profits. Here is how the pieces connect.
CRS Reports Your Accounts to China's STA (2026)
China's STA now receives account data from 100+ countries via CRS. 2025 started active enforcement. What overseas founders need to know.
Form 5472: The $25K/Year Penalty Most LLC Owners Miss
Foreign-owned US LLCs must file Form 5472 annually — even with zero revenue. The penalty is $25,000/year with no cap.
Estimated Tax Payments While Living Abroad?
US citizens abroad still owe quarterly estimated taxes. FEIE doesn't eliminate the obligation. Safe harbor rules, penalties, and the 2-month trap.
Does Your LLC Need to File FBAR?
LLCs with foreign bank accounts or signature authority face FBAR filing. $10K aggregate threshold, FinCEN Form 114, and penalties for non-filing.
Platform Income from Multiple Countries?
Earning through Stripe, Amazon, and Upwork across borders creates tax sourcing questions. 1099-K thresholds, VAT obligations, and reporting gaps.
How Do Tax Treaty Tie-Breaker Rules Work?
Two countries claim you as tax resident. Treaty tie-breaker rules resolve the conflict through a 4-step cascade. US-specific scenarios explained.
EIN vs ITIN: What Non-Resident Founders Need
An EIN identifies your US business entity. An ITIN identifies you as a foreign individual for US tax purposes. When you need each one.
Form 5472 for Non-Resident LLCs: The $25K Penalty
Form 5472 is required for every foreign-owned US LLC. The penalty for missing it is $25,000 per form per year. Filing guide, deadlines, and cost breakdown.
QSBS for Cross-Border Founders: $10M Tax Exclusion
QSBS Section 1202 offers up to $10M in capital gains exclusion — but cross-border founders face hidden traps around entity, residency, and holding period.