@Diana B.If you will be purchasing property in the U.S.A. while residing in Canada, then before you even get on a plane, you need to figure out your long term strategy (i.e. to you plan to keep all earnings in-country to grow your business or do you need to bring the money home) and the best organisational structure to fit your current situation and help you realise your objectives.If you search Canadians buying real estate in the US here on BP you will find several threads which raise some of the ownership considerations when investing abroad (control of repatriation of funds; taxation; liability, etc).  

In the future, I will probably set up an LLC and use that to hold these, which would reduce the audit risk (even though it is the same business and form over substance) and then elect S corp taxation so not all of it will be passed through as social security/Medicare wages.

To be clear, this is not pass through taxation, this is specifically a fee for the LLC based on the gross revenue of the LLC.Now that being said, I see your title states you live in CA.  

So, these investors will need to establish a US entity that is subject to US taxation.  

. :)I am a novice investor currently investing in local Tax Lien Certificates in my area.I am seeking to revitalized this discussion because the most recent post prior to my general inquires are between 2-7 months old.Please feel free to reach and network with me my professional background is taxation coupled with QuickBooks.Anyone interested in jump starting the Tax Lien Certificate forum with new introductions, and information??

I begin investing in Tax Liens approximately two weeks ago.I felt the timing was right and since I had some disposable income, I jump head first.I am still relatively new to the area and invited a fellow business colleague to assist me with accessing some of the areas; well a partnership was born.Although, we are both novices in Tax Liens, I have a solid background in researching topics (mostly taxation) but I digress so I felt mildly comfortable with this sudden turn of events.Well in hindsight, my partner and I management style is vastly different; this is where the slight nuisances started to appear. 

So, you cannot be the handyperson or hardware store delivery clerk for your IRA's flip transaction.Flipping is also something that is considered a trade or business activity, and if carried on at a regular or repeated basis the gains from such transactions are subject to taxation known as UBTI.  

You can use some strategies (such as 1031 exchanges) to defer taxation, but otherwise the profit on each flip will be subject to taxes.

TAXATION AND FINANCE CHAPTER 45.

Tax Attorney's normally deal with more complex tax related issues than a CPA.I would expect a Tax Attorney to be dealing with issues such as1) International Tax Law / Transfer Pricing2) Drafting a Private Letter Ruling(PLR) with the IRS confirming that a tax position they will tax is blessed.3) Confirming or understanding recent tax law changes / updates4) Taxation rules for companies who operate over multiple states.Best of luck