Canadian Company Expanding to Florida: Subsidiary or Branch, Permanent Establishment, Transfer Pricing, and the First U.S. Hire
September 30, 2026
A Canadian company moving into the Florida market decides first whether it will have a permanent establishment in the United States — and if it will, whether to operate through a U.S. subsidiary or a branch of the Canadian company. The answer shapes which country taxes what, the forms on both sides, the transfer pricing between the companies, the payroll for the first U.S. employee, and Florida's own corporate tax. Here is the decision and its consequences.
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