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Current scenario:

  • $150,000 CAD/yr taxable sole-proprietor income (Canadian sourced)

  • dual U.S. / Canadian citizen

  • Canadian resident

Wishful scenario:

  • 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?

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