If you’re a Canadian planning to move to the United States on an E-2 or L-1 visa, chances are you’ve been told that forming a U.S. LLC is the simplest and safest business structure.
That advice is common—and often incomplete.
The Real Risk Most People Don’t See
Most Canadians entering the U.S. market receive guidance from three groups:
- Immigration attorneys
- U.S.-based accountants
- Canadian accountants
The issue is that each group sees only one piece of the puzzle.
Immigration attorneys focus on securing the visa—often recommending a U.S. LLC as the fastest path forward.
U.S. accountants typically focus on domestic American tax rules, assuming the client is a U.S. resident with simple reporting.
Canadian accountants, meanwhile, may not fully account for how U.S. LLCs are treated under Canadian corporate tax rules or cross-border reporting requirements.
Individually, none of these perspectives are wrong. But together, they create a dangerous blind spot.
The Outcome of This Gap
When cross-border planning is missing, Canadians can face:
- Double taxation
- Incorrect reporting across both countries
- Heavy penalties and fines
- Unexpected additional tax liabilities
- Complex compliance issues that are expensive to unwind later
In many cases, the damage is not immediate—it builds over time.
That’s why proper planning from the beginning is critical.
In the next blog, we’ll break down the first major tax trap: why a U.S. LLC creates a mismatch between the U.S. and Canadian tax systems—and how that leads directly to double taxation.