Serbinski Accounting Firms

So with a ULC, a U.S. person would be able to apply the tax paid on dividends from the ULC as a foreign tax credit on their U.S. taxes, but would still be stuck without a tax credit for the corporate tax paid.

And then you also couldn't keep any money in the ULC, because you would be taxed in the ...

Thanks to all for sharing your knowledge.

To summarize:

I would not be eligible for the SBD corporate tax rate unless I am a "Canadian-controlled private corporation," with the operative words being "Canadian controlled."

However, even if I were a resident of Canada and established a CCPC, the ...

I'm currently a physician in the U.S., and U.S. citizen, but will also be working in B.C. coming up.

Most likely however, my tax home will remain the U.S., as I will probably be spending greater than half the year in the U.S., maintaining a U.S. domicile, etc.

I am considering however the ...