Looking for an account familiar with Canada & USA cross border taxation !!

., those can be held directly in the master LLC and are segregated from the secondary layer property LLC's.The tax liability of the whole structure flows to the IRA and there should not be any taxation at either level of LLC entities.You could also consider a series LLC, but there typically is not enough administrative advantage in doing so and the concept of series cell segregation - while excellent in theory - does not have the case law history as of yet to be something to rely on.

Unless you found a CPA with the exact right mix, of course.For example, I specialize in real estate, small business and am reasonably decent at ex-pat taxation.  

I am a Broker in WI turned full time investor, I use to just flip, but am now adding rentals, 4 in the last 9 mo. If I was not a broker my rental income would truly passive and not subject to self employment tax, but ...

Your IRA can be invested in a real asset to protect the principal and generate consistently solid returns.Investing in real estate with a self-directed IRA allows you to use leverage in the form of a non-recourse mortgage, which can increase the cash-on-cash return you will receive from your IRA dollars if uses wisely.The use of a non-recourse mortgage in an IRA does create exposure to UDFI taxation.  

For your tax structure you definitely need someone qualified, does not have to be a CPA, could be an Enrolled Agent or an Attorney WHO SPECIALIZES IN TAXATION OF REAL ESTATE INVESTMENTS.

It definitely is attractive investing in Canada due to exchange rate, but be sure you understand tax consequences since taxation on the gain can be heavy for non-resident, as well as, no option like 1031 Exchange in US.  

Limited liability aspect and pass through taxation.  

Contribution be a little buffer but....Contribution limits for Ira and solo limit you. 5500 vs. 18k; not including catchup.Non -recourse loan within IRA will incur some taxation (UBIT) on monthly income.

Please speak with a competent tax accountant regarding the taxation questions, as it is to lengthy to topic to disuss further.