I will assume your member is an American citizen. If not, the answer will be different. Yes, she can remain a member of your club. As a US citizen, she will still have to pay US income tax on her worldwide income. As a resident of Canada, she will have to pay Canadian taxes as well. There is a Canada-US tax treaty that eliminates some of the double taxation, or allows credit in one country for taxes paid to the other, but the specifics are too complex to provide here. Your member should consult with a tax professional with international tax expertise both here and in Canada to understand, in advance, her tax reporting obligations.

As to how this might affect your club, it won't. You will still issue her a K-1 at year end which she will use to prepare her US tax return.

Ira Smilovitz, EA

On Wed, Sep 9, 2020 at 12:08 AM Lindaman Living Trust via bivio.com <user*16710900001@bivio.com> wrote:

If she retains her green card status when returning to Canada, (and I don't know if she can), nothing will change. She is still considered a US resident for tax purposes and reports her worldwide income to the IRS. If she surrenders her green card, there may be implications for her and the club. The club could be required to withhold taxes on her earnings, whether distributed or not, but. I suspect there is a provision in the Canada-US tax treaty that provides an exemption. This is outside my area of expertise,

Ira Smilovitz, EA

On Wed, Sep 9, 2020 at 1:21 AM Lindaman Living Trust via bivio.com <user*16710900001@bivio.com> wrote: