Current scenario:
•$90,000 CAD yr taxable sole-prop income (Canadian sourced - Amazon.ca FBA)
•Income can increase
•US/CA citizen. Single. No dependents. US taxes offset by FTC's , not using FEIE.
•Ontario resident
Wishful scenario:
•Canadian Federal Corp (SBD) (15% tax)
•<$47,630 Non-Eligible Dividends disbursements (6.87% tax)
Unsure if Canadian Corp is viable because CFC, Subpart F / GILTI. How I understand CFC's is its taxed like a pass-through entity and non-deferrable. I believe Canadian Corp Tax (15%) can offset Subpart F tax liability but will still be paying US taxes. Alternatively a 18.9% CFC tax rate may exempt this (thats if I can increase the CFC's Corp tax rate).
Is a Canadian Corp still advantageous tax wise or possible? Is the "wishful scenario" still possible for a dual citizen?