That's the part you were not clear about.  I asked that in the first question.  In order for the facility to operate in Canada, it has to exist as an entity of some shape or form.  Are you saying there is a Canadian LLC?  If so, US LLC and Canadian LLC are separate legal entities for tax purposes by default.  CTB election, however, is possible to treat the foreign non-per se corporation as a disregarded entity for US tax purposes.  Please clarify the relationship between the US LLC and the facility in Canada.