The pocket consulate for life between two countries.

If you own 10%+ of a foreign corporation, it's a CFC. This triggers Form 5471 annually and potentially GILTI income — tax on certain foreign corporate profits even if you never took a dividend.

Introduced in 2017. A portion of your foreign corporation's profits may be taxed on your US personal return each year regardless of distributions. For a small content site earning under $50k/yr, GILTI is typically low but not zero.

Tax paid to Canada by your corporation generally generates a foreign tax credit on your US return. Prevents full double taxation, but the calculation is complex when GILTI, dividends, and treaty provisions interact.

If you have signing authority over the Canadian corporate bank account, it counts toward your FBAR threshold ($10k aggregate). Form 8938 has higher thresholds but applies to the corporation's value as a foreign financial asset.

Salary: T4 in Canada and W-2-equivalent in US, with withholding. Dividends: 15% Canadian withholding under treaty, US-taxable. Many cross-border owners use a mix — model both with a CPA.

A single-member Wyoming LLC is a disregarded entity for IRS — income flows onto Schedule C. No CFC rules, no Form 5471, no GILTI. Why US-based NRIs often prefer LLCs over Canadian corporations.

Federal: 15%. BC provincial: 12%. Combined: ~27% above the Small Business threshold. SBD reduces federal to 9% on first $500,000 of active income — small NRI ops pay ~11–12% combined.

When the corp pays you (as non-resident) dividends, default withholding is 25%. Under Canada-US treaty, drops to 15%. Corp deducts at source and remits to CRA.

Charge the corp a management fee for your work. Deductible by corp, taxable to you. Treaty withholding: 15%. Must be arm's-length and commercially reasonable — CRA scrutinises related-party fees.

Six months after the corp's fiscal year end. First-time filers choose their year end. Many NRI corps use January 31 to maximise time between year end and deadline.

Money kept inside the corp is taxed only at the corporate rate (~11–12%). Makes incorporation tax-efficient if you don't need to extract all profits immediately — it compounds at lower rates inside.

A director-only arrangement (no shares) creates zero personal tax exposure. They sign Articles of Incorporation, appear in the registry, no income, no reporting unless the corp pays them.

Licensed in both countries (or has a partner who is). Ask: "Do you file both T2s and US returns for foreign-corporation owners?" If they hesitate, move on. Also ask if they've handled GILTI calculations for small businesses.

Cardinal Point Wealth, MNP Cross-Border Tax, Aylett Grant Tax (Vancouver), KPMG private client cross-border. Affordable: search "cross-border CPA Canada US NRI" — boutiques charge $300–600 for initial consultation.

Tax residency status both countries. Which structure minimises combined tax. Whether GILTI applies. How to pay yourself with minimal withholding. Whether your CA relative as director creates issues. Get it in writing.

Initial consult: $300–600. Annual T2 (simple): $800–1,500 firm / $300–600 solo. US return with Form 5471: add $500–1,000. Once earning seriously, all fully deductible by the corp.

CRA's non-resident corporation guide (canada.ca/cra), IRS Publication 542, full Canada-US Tax Treaty text. Dense but useful before you spend money on a CPA.