Business and Entity Terms: US, Canada and India Tax Glossary

Business and entity terms are where cross-border founders get tripped up first, because an "LLC" has no Canadian twin, a "Private Limited Company" has no U.S. label and each country issues a different business number. This glossary defines the main business and entity terms in plain English, maps them across the three countries and links to the guide that handles the filing.

Business and entity terms at a glance

Terms A to D

Annual report (Illinois)

Illinois LLCs and corporations file an annual report with the Secretary of State to stay in good standing, listing the registered agent and the managers, members or officers. Missing it can lead to administrative dissolution. See annual report and registered agent.

Equivalents: Canada, annual return. India, annual filings with the Registrar of Companies.

Articles of organization and incorporation

The articles are the public document that creates an LLC (articles of organization) or a corporation (articles of incorporation) once filed with the Secretary of State. In Canada the articles go to Corporations Canada or a province; in India incorporation is filed through the Ministry of Corporate Affairs portal. See start a business in Illinois.

Assumed name (DBA)

An assumed name is a trade name that differs from the legal name. In Illinois, corporations and LLCs register it with the Secretary of State, while sole proprietors and partnerships file with the county clerk. See assumed name and county clerk filings.

Authorized capital and paid-up capital (India)

Authorized capital is the maximum share capital an Indian company may issue, and paid-up capital is the amount shareholders have actually paid. When a foreign investor subscribes for shares, the receipt of funds and issue of shares are reported under FEMA. See FDI and FEMA reporting.

Beneficial owner

A beneficial owner is a person who ultimately owns or controls a company, typically through ownership of 25 percent or more or substantial control. After FinCEN's final rule effective August 14, 2026, U.S. companies do not file BOI reports, but banks still ask. See beneficial ownership reporting 2026.

Branch

A branch is an office of a foreign company, not a separate legal entity. A foreign company operating a U.S. branch is taxed on income effectively connected with a U.S. trade or business and may face branch profits tax unless a treaty applies.

Equivalents: Canada and India also tax foreign branches on locally sourced profits.

Business Number (BN)

The BN is Canada's nine-digit business identifier, with program accounts added for GST/HST (RT), payroll (RP) and corporate income tax (RC). See CRA My Account and Business Number.

Equivalents: U.S., EIN. India, entity PAN, TAN and GSTIN.

C corporation

A C corporation is a separate taxpayer that files Form 1120 and pays federal tax at 21 percent. Illinois adds corporate income tax at 7 percent plus 2.5 percent replacement tax. Dividends are taxed again to shareholders. See Forms 5472 and 1120.

Equivalents: Canada, a corporation filing T2. India, a company filing ITR-6.

Canadian-controlled private corporation (CCPC)

A CCPC is a private corporation controlled by Canadian residents. It can claim the small business deduction on active business income up to the business limit. See small business deduction and corporate tax.

Certificate of good standing

The Illinois Secretary of State issues a certificate of good standing to show that an entity is current on its annual report and fees. Banks, landlords and other states often ask for it, and registering in another state as a foreign entity normally requires a certificate from the home state. See foreign qualification in Illinois.

Corporate Identification Number (CIN) and Director Identification Number (DIN)

The CIN is the 21-character number the Registrar of Companies gives a company, and the DIN is a unique number for each director. Both appear on filings made on the MCA portal. See Private Limited Company compliance.

Disregarded entity

A single-member LLC is "disregarded" for federal income tax unless it elects corporate treatment, so the owner reports its income directly. A foreign-owned disregarded LLC must still report related-party transactions on Form 5472 with a pro forma Form 1120. See foreign-owned LLC tax and reporting.

Terms E to O

Employer Identification Number (EIN)

The EIN is the nine-digit federal tax number for a business, requested on Form SS-4 and needed for banking, payroll and returns. Foreign founders without an SSN or ITIN have a separate application route. See US bank account and EIN for foreign founders.

Entity classification election

Form 8832 lets an eligible entity choose how it is taxed, such as an LLC electing to be treated as a corporation. Electing S corporation status uses Form 2553 and can be filed by qualifying eligible entities. See US business entity types and tax forms.

Fiscal year-end

A business's tax year can differ from the calendar year. U.S. corporations may elect a fiscal year, a Canadian corporation sets a fiscal period of up to 53 weeks, and Indian companies generally follow April 1 to March 31. Matching year-ends across a group makes consolidation and transfer pricing documentation easier.

Foreign direct investment (FDI) reporting

When a non-resident invests in an Indian company, FEMA requires reporting of the investment and an annual foreign liabilities and assets return. See FDI and FEMA reporting.

Foreign qualification

A company formed in another state or country must register with the Illinois Secretary of State before doing business there. This may also make it a "foreign reporting company" for BOI purposes. See foreign qualification in Illinois.

GST registration

Businesses in India and Canada register for GST once their supplies exceed a threshold and must collect and remit the tax; the GST number in India is a 15-character GSTIN. See GST registration and returns in India and GST/HST registration in Canada.

Equivalents: U.S., a state sales tax permit.

Individual with significant control (ISC)

Canadian federal corporations generally keep a register of individuals with significant control and report them to Corporations Canada. See corporate annual returns and registers.

Equivalents: U.S., beneficial owner. India, significant beneficial owner.

Limited liability company (LLC)

An LLC shields its owners from the business's debts and is taxed as a sole proprietorship, partnership or corporation depending on its election. Illinois LLCs file articles of organization and an annual report. See LLC vs corporation in Illinois.

Equivalents: Canada has no LLC. India's LLP is the closest in function.

Limited liability partnership (LLP)

An Indian LLP is a body corporate that limits partners' liability and files annual returns and statements. See LLP compliance.

Nexus

Nexus is the connection that obligates you to register or pay tax in a jurisdiction. Illinois uses a $100,000 receipts test for remote retailers from 2026. See multistate tax residency and nexus.

One Person Company (OPC)

An Indian OPC has a single shareholder and a nominee. Compliance is lighter than for a regular private company, but conditions apply to who can form one and when it must convert, so ask your CA before choosing it. See entity options in India.

Operating agreement

The operating agreement sets out how an LLC is owned and run. Illinois does not require you to file it, but banks usually ask for it. See LLC vs corporation in Illinois.

Terms P to Z

Partnership

Two or more owners carrying on a business. The U.S. partnership files Form 1065 and issues Schedules K-1; Canada uses the T5013; an Indian partnership firm is taxed as a firm. See corporate tax and entity types compared.

Permanent establishment (PE)

A PE is a fixed place of business or dependent agent in another country that gives that country the right to tax business profits under a treaty. See US-India business structures.

Private Limited Company (India)

An Indian Private Limited Company restricts share transfers and limits members' liability. It generally needs at least two directors, one of whom is an Indian resident, and files annual financial statements and an annual return. See setting up a business in India.

Equivalents: U.S., closely held corporation. Canada, private corporation.

Pro forma Form 1120

A foreign-owned disregarded LLC files a Form 1120 that is mostly blank with a Form 5472 attached to report reportable transactions with its foreign owner. It follows the corporate return timetable, so an extension on Form 7004 is common. A missing or late filing can bring a significant penalty, so calendar it. See Forms 5472 and 1120.

Registered agent

Illinois requires every LLC and corporation to maintain a registered agent with an Illinois address who receives legal papers. Canada and India require a registered office instead. See annual report and registered agent.

Registrar of Companies (ROC) and the MCA portal

India's Ministry of Corporate Affairs runs the MCA21 portal where companies and LLPs incorporate and file annual financial statements and annual returns with the Registrar of Companies. Late filings attract additional fees, so many founders keep a compliance calendar. See Private Limited Company compliance.

S corporation

An S corporation is a corporation that elects pass-through treatment on Form 2553. Its shareholders generally must be U.S. citizens or residents, so a nonresident alien cannot own shares. See US business entity types and tax forms.

Sole proprietorship

An unincorporated one-owner business. In the U.S. it is reported on Schedule C, in Canada on Form T2125 and in India as business income of the proprietor. See Canada sole proprietor guide.

Subsidiary

A subsidiary is a separate company owned by a parent. A U.S. subsidiary of a foreign parent files Form 1120 and Form 5472, and the group should document pricing between related parties. See Forms 5472 and 1120.

Transfer pricing

Transfer pricing is the pricing of transactions between related companies, which must be at arm's length. India has detailed documentation rules; the U.S. uses Form 5472 and Canada uses Form T106. See India transfer pricing basics.

Unlimited liability company (ULC)

Alberta, British Columbia and Nova Scotia allow ULCs, whose shareholders can be liable for the company's debts. A ULC may be treated differently in Canada and in the U.S., sometimes with surprising results, so take advice on both sides before using one. See incorporating in Canada.

How we can help

From the Aurora, Illinois area we help founders choose an entity, obtain an EIN, register in Illinois and handle ongoing U.S. tax filings, and we coordinate with your Canadian CPA or Indian Chartered Accountant for home-country filings. See business formation and registrations and business tax returns and planning. Browse the full tax and compliance glossary for the other term sets.

Frequently asked questions

General information only. It is not tax, legal, accounting or immigration advice for your situation, and rules change; confirm the current rules with the official source or a licensed professional in the relevant country.