When it comes to taxation, particularly cross-border taxation the rules can be very complex.
Firstly, I'd like to let you know that I am a Canadian investor who's been investing in the U.S. for over 7 years but I AM NOT AN ACCOUNTANT OR LAWYER. The information I'm giving is based on my experience and expertise as an investor.
The most important thing to keep in mind is that it's not one size fits all. Everybody has a different tax situation and in order to determine the correct structure one would need to know a fair bit of information before they could assess the ideal setup for you. Some of the things that come into play are:
a) Are you flipping or buying to hold (Passive income is taxed differently than earned income)
b) What do you have for assets (do you need a corporation for asset protection and if so what type is best for your situation)
c) How are your Canadian assets held? Corporately, personally?
d) What type of write-offs do you have?
The above are just a few of the things that come into play when determining what type of entity(s) you require to strategically reduce taxes and liability issues.
If someone tells you a "solution" without knowing your situation RUN! You should always consult with a cross-border specialist prior to making these decisions.
I have some great cross-border accountants on my team who can guide you. Let me know if you require their help.
