Canada to treat LLLPs and LLPs from Florida and Delaware as Corporations for Taxes

– Canada Revenue Agency (CRA) announced that limited liability limited partnerships and limited liability partnerships organized under the laws of Florida or Delaware will be taxable as corporations for Canadian income tax purposes.
– US LLLPs and LLPs with Canadian owners will now be subject to double income tax, as they will be treated as pass-through entities by the US but as corporations by Canada.
– Transitional relief has been announced so that US LLLPs and LLPs can be treated as pass-through entities for Canadian tax purposes retroactively if certain conditions are satisfied.

https://www.williamsparker.com/insights/canada-treat-florida-delaware-lllps-llps-corporations-tax-purposes/