Where a US LLC makes an election to be treated as a corporation for US tax purposes, will the making of the election have Canadian tax implications?
CRA indicated its understanding that this would not impact the US legal attributes or the laws regarding the governance or operation of the LLC. As from a US legal perspective, the LLC remains the same legal entity after checking the box as it was before it made the election, the election would not result in a disposition of either the units held in the LLC by its members or of the LLC’s assets for Canadian purposes.