For a US citizen working/living in Canada as a 100% owner/shareholder of a Canadian professional corporation (i.e. a CFC) it seems there are 2 ways to report corporate earnings:
1. under Section 954 (c) (1) (I) as personal services contract income, or,
2. under Section 954 (e) as base company services income.
The latter would not be reportable if services are provided within the country of incorporation. Obviously this would be the preferred choice for the owner.
Is there any reason why #2 above is not a valid way to report earnings?
Subpart F income
Moderator: Mark T Serbinski CA CPA