Canadian Contractor in the U.S.

[uscdntax]

Hello

I have been offered a contract position in the U.S. I am a Canadian Citizen. I was hoping someone could advice on the best structure for the contract. I contract through my Canadian corporation in Canada but I have read that it may be more tax efficient to set up an S corporation in the U.S. Or would it be better to just operate as a Sole Proprietor?

I am particularly concerned about "Subpart F Income"; I read about this on this website. If I am being paid through my Canadian corp, would I be liable for this? It seems like double taxation to me. Would I be able to claim foreign business income tax credit in Canada? My understanding is that for subpart F income, you are taxed as if the profits of the company had been distributed.

In addition, would it be better to just become a Canadian non-resident for tax purposes in this situation?

Thanks in advance.