I’m based in Quebec, Canada, and I’m a Canadian citizen only. I currently have:

• a U.S. C-corp in Ohio
• a Canadian holding company in Quebec

I’m slowly getting into buying U.S. rental properties and want to set up the best possible structure from a tax and asset-protection standpoint.

Right now, I’m planning to dissolve the Ohio C-corp and create an LLC instead for wholesaling and another LLC for my future rentals.

My main questions are:

• Should my Canadian holding company be at the top of the structure?
• Should I also create a U.S. holding company?
• What should own what?
• Where is the best place to form the LLC(s) and any holdco(s)?
• Is there a common structure that works best for Canadians investing in U.S. real estate, especially from a tax efficiency perspective?

I’m looking for advice from:

• Canadian investors who buy rentals in the U.S.
• Cross-border real estate investors
• Cross-border CPAs / tax professionals / attorneys

I’m trying to build this the right way from the start and avoid creating a structure that causes unnecessary tax issues between Canada and the U.S.

Would really appreciate hearing what structure has worked best for others in a similar situation.