I actually gave you misleading advice for which I apologize. I dont think you can buy at 16:01 on the pre-ex-dividend day,this would probably settle the stock trade before the record day and give you the dividend. I believe(and I will test soon) you need to sell 15:59(maybe a little later if you are paranoid about gains in the after hours) then buy the shares back on the gap down on the ex-div date(maybe with a opening only order?) I wonder if somebody has experience with this
non-US citizens/residents are exempt from paying capital gains taxes in the US. they SHOULD declare that in their home country, though. regarding dividends, brokers are required to withhold dividend taxes. if you open the account as a non-US citizen/resident, you may get a tax credit in your home country depending on tax treaties.
You need to find a broker that will do the following (not sure if this is done much anymore, but it was done a lot in the 1990s). 1. Sell your stock before it goes ex-dividend to the brokerage firm. Settle regular way. 2. Then buy the stock back from the broker at the price you sold it minus the dividend. Settle this seller's option 4 (i.e., T+4). The broker pockets a commission and takes care of all the tax problems. Obviously, you gotta be big and do size otherwise it does not make any sense for a broker to do this for you.
Canadians cannot avoid a 15% withholding on US dividends. But you get a dollar for dollar TAX CREDIT for all dividends withheld by the IRS... So if you have a competent accountant... it's a wash.
You still can use the SSF for either the ETF future or the standard individual contract to circumvent the dividend which removes the dividend tax problem. If you are a big enough client for your firm the T+ 4 trade can work as well.