Small Business & Self-Employed Tax

Entity Selection and Expansion Planning

The preferred structure depends on ownership, activities, financing, profit expectations, treaty access, state or provincial exposure, repatriation plans, and exit strategy. We compare alternatives before formation or restructuring.

• Canadian corporation entering the United States
• US corporation establishing Canadian operations
• Subsidiary, branch, partnership, or direct-operation comparisons
• LLC classification and Canadian hybrid-entity concerns
• Permanent establishment and income-sourcing analysis
• Cross-border financing and payment flows

E-Commerce and Amazon Sellers

Inventory, employees, contractors, sales volume, marketplace activity, and other contacts might create state registration, sales tax, income tax, franchise tax, or gross-receipts obligations.

• Physical and economic nexus review
• Amazon FBA inventory-state analysis
• Sales tax registration and filing coordination
• State income and franchise tax review
• US federal and Canadian corporate reporting
• Bookkeeping and marketplace reconciliations

Foreign-Owned US Entities

Foreign ownership and related-party transactions often create special US reporting obligations. A foreign-owned disregarded entity might need a pro forma Form 1120 with Form 5472 even when it has little or no operating activity.

Cross-Border Payments

• Dividends, interest, royalties, rent, and service fees
• Canadian Part XIII and Regulation 105 considerations
• US withholding and information reporting
• Treaty-rate documentation
• Related-party and transfer-pricing considerations