$150,000 CAD/yr taxable sole-proprietor income (Canadian sourced)
dual U.S. / Canadian citizen
Canadian corporation qualifying for small-business deduction for lower corporate tax rate (15%)
$47,630 Non-Eligible Dividend Salary (6.87%)
I'm not sure if a Canadian corporation is viable because of U.S. codes relating to CFC (Controlled Foreign Corporations) and Subpart F / GILTI tax. With "current scenario" what's the most economical tax strategy? Is a Canadian corporation still advantageous, tax-wise?