Investing into U.S. Syndications as a Canadian

[Ken James]

As the title mentions, I'm a Canadian resident looking to invest into MF syndications in the United States.

I've done some research and it looks like there's a few different business / tax structures that can be used to make this work, but I have some questions regarding the implications or potential issues that may come up:

A common structure is setting up a U.S. company that owns the property, and this company is fully owned by a Canadian Hold Co.

1. Is there a taxation for moving those U.S. funds into the Canadian Holding Company and into Canada? Do the funds need to be kept in the U.S. company to avoid a double taxation?

2. Accredited investor is preferred by most syndications - does this mean you need to have a certain amount of funds in the U.S. company to qualify as an accredited investor (to be clear I qualify by all definitions but that would be for my Canadian company and Hold Co.) I'm wondering if you need to have the actual funds or income in the U.S. with this new company thats being setup.

3. Will Syndicators have an issue lending to foreign owners who own U.S. entities? Is there any potential reasons why this would come up or would I be categorized the same as any other U.S. investor who's investing through a company?

Appreciate any thoughts and feedback. Navigating this as a Canadian can be difficult as it's a unique situation and I haven't seen much information regarding this.