Income from US corporation - Canadian res - treaty question

[puzon23]

Hello all,

I have a very particular situation. I am a permanent resident of Canada but because I used to live in the US I have my own C corporation back there. My wife and I have a 100% ownership in it. My corporation still has clients that we serve and we get our income from there. I'm trying to do some tax planning for next year already to make sure I do the right thing tax wise. I have a couple of options to get paid from my US corp. I could either do a management fee or give myself a regular salary. From the Canadian perspective which one would be better tax wise? What would the treaty say? Please note that I am NOT a US citizen (Polish citizen) and a resident of Canada. For last year I did my Canadian return through H&R Block and my management fee from last year was not even calculated into my Canadian return, however, I was only a part year resident of Canada last year. I did that through the online software so I have no explanation as to why it was as such. So if I continue paying myself through management fee does that mean that I won't have to pay taxes on it in Canada (I will pay it in the US). Is there a threshold that I can't go over? Can someone please advise what would be the best way to go about this.

Thanks a lot!

MJ