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Choose the right structure. Avoid costly mistakes. Build a foundation that supports your growth.
Start with the right foundation from day one.
As your business evolves, your structure should too.
Structure matters even more across jurisdictions.
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"When we were looking to open up business in the USA, Lodder CPA was highly recommended by our Canadian CPA as a Company we could trust to ensure that our business would be setup correctly for US Taxes and protected. Kyle has been fantastic to work with and his connections have been invaluable in getting incorporated in the USA quickly, professionally and in compliance with the US legal system. Highly recommend!"
Alex Fortin
NDS Integration
"Lodder CPA helped greatly with our company's U.S. expansion from Canada. They have excellent knowledge and execution, as they collaborated well with our other advisors including our immigration attorney and Canadian tax advisor to ensure a smooth transition into the U.S. including optimizing our worldwide tax position."
Brent Larsen
Steep Hill Equipment Solutions
Find answers to frequently asked questions about our services and international taxes.
This income is included on your U.S. tax return. It’s also possible that this income is taxable in the foreign country. You would need to determine the tax implications with your tax professionals in the U.S. and abroad. If there is an income tax liability in the foreign country, then you may be able to obtain a foreign tax credit on the U.S. return to avoid double taxation.
Possibly. However, there may be anti-tax deferral provisions such as Global Intangible Low-Taxed Income (GILTI) that could apply that cause you to pay current tax on this non-U.S. income. You should seek tax advice to avoid onerous tax provisions.
No. GILTI applies to corporations who would otherwise be able to defer U.S. corporate income tax until a dividend is paid. Income from the partnerships or pass-through entities is includable on the U.S. company return in the year it is earned.
Under current law, there is no tax since the U.S. corporation would obtain a 100% dividend deduction.
Yes. U.S. corporations benefit from tax incentives such as deducting a portion of foreign-derived intangible income (FDII), linked to intangible assets held domestically. Additionally, the Interest Charge Domestic International Sales Corporation (IC-DISC) provides substantial tax savings for exporting U.S. products. Unlike tax shelters, IC-DISC facilitates permanent tax savings by transferring income through export sales commissions.
Whether you’re setting up in the U.S. or optimizing an existing structure, we’ll help you create a foundation that supports your growth.
