This whole move is about corporate governance. The US makes it really easy to start or manage corporations and the courts are (mostly) streamlined and predictable, especially the chancery courts in Delaware. Cayman Islands adopted many of Delaware's legal approach to corporations in 2016 to make the island more business friendly rather than just a tax haven, and they've got a foot in the Latin American market. Singapore is the SEA equivalent of Delaware.
Nothing else much to it. In reality they're all going to have to register to do business in Canada/California/whatever and pay their taxes anyway. Structuring the parent in one of those jurisdictions just makes the legal wrangling about ownership and stock classes safer and more predictable to both investor and founder.
> “It’s the Valley-or-bust mentality that breaks the ecosystem and really hurts Canada,” Gomez said.
Canadian pride isn't enough to keep a company in Canada. There are real and significant economic incentives to move elsewhere. That said, it's disappointing that YC no longer supports Canadian companies.
Canadian companies actually have great economic incentives. The government will pay like 60% for your dev salaries that go towards R&D (SR&ED).
Plus you don’t have to worry about getting audited if you tweet the wrong thing.
Presumably it continues to support them the same way it supports 386 companies headquartered in Europe, 218 in South Asia, 217 in Latin America, 106 in Southeast Asia, 87 in Africa, 71 in MENA, 23 in East Asia, and 14 in Oceania, all locales where you previously had to do a flipped company structure to participate in YC.
Economic incentives are only one of the many incentives weighing on the scales. There are others.
Like which?
Attractiveness to talent?
Fairly senior dev, US citizen here (20 years experience).
After what I've seen this past year, but more the past month, I will work for peanuts for a path to citizenship in Canada. US in 5 years is not a place I want to be, looking into all options and very serious.
The lifestyle difference is real but the income difference is enough to sway most people to the US. If Canada can close the gap on that I'd say it can become an even more attractive place for global tech talent than the US because of its overall better livability.
If you have skills in one of the many categories, and with 20 years in tech you should, get the offer. Once armed with an offer from a Canadian company you can handle the visa at the border. For Quebec-based companies you have to have a handle on French but for the rest of Canada it's a skills and education based system for getting permanent residency.
This is extremely misleading. YC still backs Canadian founders (and other international founders). There must have been one too many painful experiences investing in companies based in Canada. Creating or converting to a US-based entity is a standard ask for most international founders who want to participate YC and I suppose something has changed such that Canada is no longer an exception to that.
Important added context here: the list went from US, Cayman, Singapore, Canada to US, Cayman, Singapore. It's not as if YC was generally investing in non-US based entities before. Canada was an exception and isn't anymore.
We're a global employer, and just employing people in different jurisdictions is kind of a nightmare (totally worth it, though). I can't imagine how much of a pain it must be to try to manage investment stakes in foreign corporations.
It's a weird change though. Canada is one of the most investor-friendly and startup-friendly jurisdictions I can think of. If you want to grow quickly, you need to be thinking about how to get an office set up in places like Calgary (lots of machine-learning talent there), Toronto, and Vancouver, and when you do so you'll find the government incentives and lower wages lead to you spending about half on total compensation versus a typical American startup hub.
I worked at a place that expanded into Calgary and picked up a bunch of ML engineers with oil-and-gas backgrounds (who were eager for something outside the energy sector) and the government picked up half of the payroll tab for several years. There is also, of course, no health insurance benefits to worry about.
There are definitely still health insurance benefits (I'm Canadian). Yes, our doctor and hospital visits are covered, but many things are covered by employer paid insurance (or not at all):
- prescription medicine
- dental
- vision
- mental health
- things like physiotherapy
Yeah, correct, but it's not going to be a $4000/mo line item expense for the employer per employee.
I don't have to deal with this as we are a (very) small business but it's a major headache for larger small businesses. Basically, as an employer it simply isn't fun to be forced to be in the "providing access to healthcare" business when that's not your core business.
> Canada is one of the most investor-friendly and startup-friendly jurisdictions I can think of.
Other comments in this thread make it sound like an absolute nightmare. So which is it?
Much like the US, the regulations and culture varies depending on which province (state) you're in, so someone starting a business in Alberta could have a very different experience than someone in Ontario.
Somewhat. Our provinces have fewer rights, powers and responsibilities than US states. The experience is more homogenous.
It's only a nightmare if you hate all taxes and labour rights. So, you know, YC
> Our provinces have fewer rights, powers and responsibilities than US states.
It's complicated. In theory, US states have more rights and powers ("The powers not delegated to the United States [...] are reserved to the States" [0]), but in practice, the Commerce Clause lets the Federal government do essentially anything that it wants. Canada's provinces are only given control over a specific set of topics [1], but their powers are almost absolute in these areas, since the courts almost never let the Federal government interfere.
So for labour code specifically, US companies need to adhere to both Federal and state labour codes, while Canadian companies only need to follow a single provincial labour code. (There is a Canadian Federal labour code, but that only applies to Federally-regulated companies, and those companies don't need to follow the provincial labour codes)
[0]: https://en.wikipedia.org/wiki/Tenth_Amendment_to_the_United_...
[1]: https://en.wikipedia.org/wiki/Constitution_Act,_1867#Part_VI...
You can still run a company from Canada under these terms, the same way every international YC batch company runs --- you can just go to the YC directory and select for EMEA, LATAM, APAC, &c. There's hundreds of them.
Since this is purely about ownership structure and equity governing law, I'm curious what the intersection you're seeing between these terms and "labour rights" are. We're a US company with employees in Europe (not even an HQ in Europe, just employees there), and I've learned more about European labor law idiosyncracies over the last few years than over the whole rest of my career, because I've had to.
> You can still run a company from Canada under these terms, the same way every international YC batch company runs
Having a Canada-registered company is usually required to get government grants and loans from Canadian banks, although that's probably not very important to VC-backed companies. There are also some tax advantages to running a Canada-registered company if you're based out of Canada, plus it's much easier to find a local professionals (lawyers, accountants, etc.) familiar with Canadian corporations than US corporations.
None of these issues should cause too many problems, but if given a choice, as a Canadian I'd certainly prefer to run a Canada-registered company over a US-registered one.
I'm sure a lot of British people want to run UK-registered companies! I'm not saying Canadians wouldn't rationally prefer to have the option of taking investments in a Canadian corporation, just that it doesn't look like there's a lot more to this than details for your finance person, and that it's the same deal every other country gets.
Read the thread: clearly a lot of people are reading this as "you can't HQ in Canada, your team has to move".
> There is also, of course, no health insurance benefits to worry about.
Uhh, we don't have universal coverage for everything health up here, we still have private benefits that our employers pay for as part of our compensation plans.
Life insurance, dental, vision, prescriptions, physio, mental health, critical illness etc..
It might be less than in the US, but it's not "no health insurance benefits to worry about".
Well, it's fully possible to be self-insuring in these areas. Prescription assistance is probably the one significant benefit as physio, mental health and the like can be of limited reimbursement (judging from what I've seen).
The key issue is that the core of one's health insurance is not dependent on the employer or even being full-time employed. This provides tremendous flexibility. And I suspect not having things like pregnancy being seen as preexisting conditions is a big win for parents-to-be.
Age or low-income (I think) provide provincial or federal assistance independent of employment also. Medical expenses are also far easier to deduct on taxes in Canada vs. the US.
Doesn't it seem likely that tax treatment has more to do with this than benefits? People are reading this like YC isn't investing in companies HQ'd in Canada, but there's no evidence of that! I look at a set {US, Singapore, Cayman} and what I think is "this is about taxes". Maybe especially tricky for YC since such a huge fraction of their portcos are pre-revenue.
The key question is whether they make non-US-ians move to the Valley to participate. Or, rephrasing, leave their home country to move to whichever piece of YC is cutting the check.
Again: there were 4 countries, total, in the standard YC deal terms. Now there are 3. There are many hundreds of YC companies headquartered overseas.
The standard move in this situation is that you form a US Delaware C Corp and make your HQ a subsidiary.
Delaware vs. Cayman for LatAm startups: https://news.ycombinator.com/item?id=46686745
There could be many factors at play here so it’s not clear what the main issue is. However, from experience, US VC funds typically come from other US institutions and so it’s an easier sell when the corporation is US-based. Rules and regulations are more well understood and less complex for funds. The article states the requirement is to flip the structure to have the parent company based in one of the 3 countries mentioned. Presumably, better business/returns/policies
That's truly saddening. I hope there will be more VC backing in Canada because the talent is definitely there.
We in the VC, PE, and Growth Equity space invest using other people's money.
The people who have capital in Canada are uninterested in funding Canadian domiciled GPs - they mostly end up choosing American asset classes because of high returns.
Institutional investors like the Ontario Teachers Pension Plan and CDQP tend to target asset classes outside of Canada due to their returns requirements being in the double digits range.
Edit: Can't reply
> TBF, the OTPP has a huge home bias - they’ve got more Canadian investments than they do US investments despite the market being less than a tenth the size
Huge by institutional investor standards but not in aggregate.
The majority of OTPP's assets are not in real estate [0] - out of $209B AUM, only $29.4B is invested in real estate globally.
Most of their Canadian assets are fixed income investments, and even then their overall Canadian assets are dwarfed by their transnational investments (primarily US and Asia).
[0] - https://www.otpp.com/content/dam/otpp/documents/reports/2024...
> Institutional investors like the Ontario Teachers Pension Plan and CDQP tend to target asset classes outside of Canada due to their returns requirements being in the double digits range.
TBF, the OTPP has a huge home bias - they’ve got more Canadian investments than they do US investments despite the market being less than a tenth the size.
They couldn’t target a higher proportion of Canadian assets while remaining reasonably diversified.
Or Canadian real estate.
Most institutional investors limit real estate to around less than 5% of their portfolio.
So what's the upshot? No Canadian VCs? I guess there's always ClearCo LOL
> No Canadian VCs
Pretty much.
Israel [0], China [1], and increasingly India [2][3] worked on resolving this issue by establishing funds of funds that partnered with private sector players by matching dollar-to-dollar with them to help build a VC ecosystem.
It's the same problem in the EU as well despite ECB proclamations. Heck, Norway's (ik not EU, it's EFTA) PIF has been conspicuously absent from any sort of statment of solidarity for Greenland unlike their Swedish, Finnish, and Danish peers because 25% of Norway's budget is dependent on the PIF maintaining double digit performance.
Edit: can't reply
> I think our biggest problem in Canada is total addressable market is small [...]
Israel is even smaller than Canada - 9 million people versus 40 million - and the median Israeli remains poorer [4] than the median Canada [5]. That didn't stop Israel.
Size of home country doesn't matter. The only difference is vision (and moreso lack thereof amongst Canadian and European decisionmakers).
> I don't think an Israeli founder would have trouble moving to the US if they wanted to.
They don't. In fact, Israel had an India-style brain drain to the US until the 2010s.
Heck, a little over a decade ago I had acquaintances of mine in TLV seriously considering moving their entire family to Sunnyvale for a $150k base salary job instead of earning $90k. They ended up deciding to become founders instead.
> 900M in the EU
The EU only has a population of 450M people.
[0] - https://www.yozmagroup.com/overview
[1] - https://english.www.gov.cn/news/202512/26/content_WS694e4e56...
[2] - https://idtalliance.org/
[3] - https://rdifund.anrf.gov.in/
[4] - https://www.ynet.co.il/economy/article/bjn8ppfz2
[5] - https://www03.cmhc-schl.gc.ca/hmip-pimh/en/TableMapChart/Tab...
I think our biggest problem in Canada is total addressable market is small.. We're 40M people (compared to what, 350M in the US, and 900M in the EU), and we're directly next door to the largest startup economy in the world.
So not only do we have fewer customers, we're competing against an economic juggernaut that shares our broad business rules, our culture and language (with one exception) and can market to us through all our media channels with very little friction.
So unless you're in health care or some other regulated field that a US startup can't just expand into easily, it's a tough go.
Israel, like the parent poster said, is even smaller. I don't think an Israeli founder would have trouble moving to the US if they wanted to.
Is it politically motivated or does it have to do with Canadian tech not requiring investment because of its stability?
I would bet it's politically motivated, YC strikes me as money at all costs, and very dismissive of the techno feudalism they help support
I can't speak for YC, but legal overhead is an operational pain.
It's safe to assume YC will continue to fund Canadian founders, but they'll now require them to incorporate in Delaware, Singapore, or the Cayman Islands - none of which is significantly difficult for a founder. You could literally make a US Corp via Firstbase in a couple of minutes [0]
Shopify is basically the only really successful Canadian start-up.
It's very hard to run a very small business here.
>Shopify is basically the only really successful Canadian start-up.
I've heard that Shopify is by itself 10% of all Canadian tech jobs paying >$100K.
It's actually remarkable how difficult it's made. My only experience is here in BC. In a couple of years I've learned that it's practically punitive, and you have to want to do it really badly. The risk to reward ration is abysmal. I only continue because it's more of a passion project than an economically viable, sensible project. It could become one eventually, but my god, I'd hate to be doing this without a full time job to depend on.
Can you give more details? I'm simply a sole proprietorship in Canada so not sure what I'm getting myself into.
Don’t worry too much. I’ve incorporated in AB and BC. Neither is difficult to setup or maintain. My regulatory burden amounts to about one weekend of effort per year including corporate tax filings. That’s a baseline. Harder if you employ a team (not just subcontractors) or in regulated industries where you might have environmental compliance or similar.
This is a much better summary than mine. It really is fine if you don't venture into places where various types of compliance come into the picture.
I think some things could make your work far easier than mine, but in my case there are a lot of hoops to jump through. I initially wanted to bootstrap myself in my garage, but discovered over time that this is essentially illegal and I'm required to operate out of a business address. This is also virtually forced on me because there are a variety of compounds I can't order without a registered business and accompanying business address, which is manually verified. Fine, I totally get regulations around hazardous chemicals, though in my case it seems excessive. But, if I were to summarize the things that have been most frustrating:
- Rents in industrial spaces are absurd in my area, and I suspect they are for most of Canada in any HCOL area. If you can't wing it out of your garage, your burn rate just exploded
- Getting permits has been exorbitantly slow and complex
- WorkSafeBC cooperation and inspections are a major time sink (gets better after the first stretch)
- Getting certficates to export plants is—in my opinion—unnecessarily complex and slow, such that I don't think I'll even bother at this rate
- Inter-provincial regulations and standards can be hard as hell to nail down. Asking random people on forums can yield better results than extensive google or LLM querying
- Keeping track of things like write offs and deductions can span years for single costs. I understand why, but I don't like it
- Admin and oversight often feels like half the job. I need to be on top of so many things that aren't 'the work', and it takes a lot away from focusing on making a better product
- Shipping things is expensive as hell, and I anticipate this problem will worsen over time. Not a big deal if you don't ship anything
- Depending on the type of business you've registered, the admin overhead at different times of the year can be significant
Again though, if you just go around repairing things or you provide software services, your life will be orders of magnitude simpler. I used to have a sole proprietorship here in BC providing software consulting services, and it was fine. I had one tax hiccup in something like 10 years, and it wasn't a big deal. I rarely had to think about it.
I do wonder if this friction could be part of why Canada arguably has a lack of interest and innovation when it comes to producing material goods. It's genuinely a pain in the ass to be allowed to do it by the books, and to continue operating accordingly.
Caveat: I could be lazy and stupid
Thanks for your comment. I have in my mind to start a hardware focused business in Ontario. I am a little afraid now, but hopefully, I have better luck than you.
Can you expand a bit more on how difficult it is to deliver hardware product orders to other countries? Whichever ones you have experience in.
Probably de-risking (or front-running) capital controls (tariff on FDI).
Disappointing.
Canada's economy is dominated by a few big companies because the government makes too many rules. It costs too much to start a business here. In politics, only two parties really matter. This creates a closed system where big players stay big and new competition is crushed by red tape. Regulatory frameworks impose prohibitive compliance costs, favoring established incumbents over startups. Key sectors like banking, telecom, and aviation function as protected triopolies. Political power remains centralized between two parties with overlapping establishment interests. These structural barriers effectively suffocate competition and exclude new market entrants.
What do you mean it costs too much to start businesses here? I’ve founded 3 start ups and have not had any issues with things costing too much. Not a single one of those startups needed much to get going and there was no red tape or mysterious taxes that got in the way.
Can't help but read this as "Canada's today is the US in 10 years..."
NVIDIA makes up 7% of the S&P 500 ETFs. We live in the United States of NVIDIA.
Yes but at least it's not People's Republic of NVidia, so there's that.
The U.S. also has only two parties that really matter, with overlapping establishment interests. What makes the difference?
Whether it's significant or not, YC's basic model of seed funding with ~$100k could be reproduced in Canada with $10MM or less. Unsure how this is a problem.
If Canada wanted to be serious about startups it could make trivial changes to enable it. However it's committed to becoming a dutch diseased resource colony with no value add and a macquiladora for US software companies. Relative to capital and assets, it's the least productive place on earth. The whole thing runs on riding the coattails of like 5 undergrad profs at waterloo, and a certain bank everyone knows launders cartel money and facilitates capital flight out of China.
Judging by its impact, YC is one of the greatest companies of all time. Canada isn't in that game imo.
What are the trivial changes Canada could make if it wanted to be serious about startups?
briefly: cap gains reductions. at will employment. competitive top line corporate rates that attract HQ's and IP the way Ireland did. reduce the public sector talent tarpit, tariff goods from countries that use slave labor. abolish the dairy, wheat, and syrup boards and other agriculture cartels. enforce money laundering laws against retail businesses to normalize commercial rents. reduce immigration to levels where people can integrate and actually want to make things for each other and to take the pressure off home prices. pro natal policies that create more young people with a stake in their country. make math education a national project. to name a few.
if you talk to anyone in canada who is from here and doesn't work in the public sector, the conversation quickly turns to whether they're planning to leave and how far along they are. the way it's going, they're going to have to bar the exits.
Wonder if the founders not being US citizens or possibly even residents will hinder their ability to maintain their company. Or, whether this change increases the likelihood of being replaced when the startup shows some success.
Also, being foreign in the US is a concern at the moment. Hell, being native in the US is a concern at the moment...
There's probably no nationality easier for tech workers to migrate to the U.S. with than Canada, though. (And vice versa.)
Not at all. The only benefit Canadians get compared to others is the opportunity to work for employers on TN status which is a temporary non-immigrant-intent work visa. You're not even allowed to want to immigrate if you have one. And given the political climate there's a chance it will go away at any time.
> The only benefit Canadians get compared to others is the opportunity to work for employers on TN status which is a temporary non-immigrant-intent work visa.
That doesn't strike me as "not at all" when the TN status is 1/ effectively a work visa, whether you like the strings attached or not, and 2/ a foot in the door that lets you move to a more permissive status down the line. A Waterloo or UofT grad can go from applying to a US job to their first day in a few weeks, and the only interaction they'll have with the immigration system will be getting asked for paperwork at the border. Compare that to a British or Japanese new grad, for whom there is essentially very few options unless they have excellent connections or that they display enough extraordinary abilities to be eligible for O-1.
Yup, such visas (going both ways) are based on the NAFTA/CUSMA agreement and probably live or die with that agreement. Uncertainty limits what businesses and people can/will do, and the sudden loss of work/residency permission would be really annoying for the families involved.