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In the recent past, US taxpayers who wanted to invest in Canada would often do so with structures that would avoid inefficient tax results on both sides of the border.  One of the common structures that was employed in the corporate context was to utilize certain Canadian corporations that were fiscally transparent for US purposes.  In Canada, such corporations only existed in Nova Scotia (as a Nova Scotia Unlimited Liability Corporation) or in Alberta (as an Alberta Unlimited Liability Corporation).  To the extent that a US taxpayer owned, say 100% of the shares of the ULC, all of the profits of the ULC would generally be fiscally transparent for US tax purposes (meaning that the US would not respect the ULC as being a separate legal entity and would require the profits of the ULC to be included in the US taxpayer’s income directly). For Canadian purposes, the ULC was treated as a “normal” corporation for taxation purposes and thus the profits were subject to Canadian tax with such tax generally being creditable against the US tax on the ULC’s profits.  The result was the avoidance of potential inefficient tax results on an overall basis.  To the extent that the profits of the ULC were repatriated to the US parent by way of a dividend, such dividends would often be subject to “treaty benefits” which would result in a reduced withholding tax rate.