I am a Canadian and own a Canadian (Ontario) corporation. Currently, I am a US resident. My Canadian company is due a large payment in 2017. If I am a CDN resident I can take advantage of the Canadian Capital Dividend account. Let's use an amount of $1,000,000 to simplify (and we don't need to worry about exchange rates). From my understanding, if I am a Canadian resident, and I have $1,000,000 in the capital dividend account, I can take the first 50% tax free. As a small business, the remaining 50% is taxed at 26.5% ($500,000 * 0.265 = $132,500). Then, the remainder I can take personally and pay personal income tax ($367,500 * 0.45 = $165,375). Under this scenario the total CDN tax paid is $132,50 + $165,375 = $297,875 for a total tax rate of 29.8%.
If I remain a US resident I can't take advantage of the capital dividend 50% tax free benefit. What are my best options to minimize the tax burden if I choose to remain in the USA? My Canadian corp can easily set up a US corp (Delaware, Nevada, etc.) if it is required.
I currently reside in NV with no state personal income tax.