Individual A, a Canadian resident, owns and operates a profitable small farm in North Dakota, U.S.A. He also has a large amount of money earning interest in an American bank. Individual B, also a Canadian resident, owns 100% of the shares of an American corporation that operates a profitable small farm in North Dakota. The corporation also has a large amount of money earning interest in an American bank.
Describe and compare the tax positions of these two individuals who conduct the same activities but use different organizational structures.