What is a Nova Scotia Unlimited Liability Company (NSULC)?
Created under the Nova Scotia Companies Act, an NSULC permits the incorporation of a company with no limit on the liability of its shareholders. The result is a hybrid entity – a taxable corporation for Canadian tax purposes and a flow-through entity for U.S. tax purposes. This allows for unique opportunities in cross-border tax planning – making it even more attractive to U.S. investors with business in Nova Scotia. Advantages of a Nova Scotia Unlimited Liability Company An NSULC is useful in transactions for a company doing business in the U.S. or Canada and where a U.S. resident has a direct or indirect interest in the NSULC. The following are some examples of the benefits of using an NSULC: Tax • A U.S. taxpayer may be able to use losses from its Canadian business as a deduction against its income for U.S. income tax purposes. • A U.S. taxpayer could use the NSULC to limit transfer pricing issues to Canada. • A U.S. individual could have a local corporate presence in Canada (avoids
