What We Do · Businesses & Entities

U.S. Tax for Businesses

U.S. tax planning and compliance for businesses with U.S. or international operations, ownership or investments. We help businesses understand their U.S. tax obligations, evaluate entity structures, plan for tax consequences and meet federal and state filing requirements.

U.S. owners of foreign companies
Non-U.S. owners of U.S. entities
Businesses operating or expanding into the United States

Outline Your Structure

Tax Advisory & Planning

Advice on U.S. tax implications, entity structures and filing obligations for businesses operating across jurisdictions. We help businesses evaluate tax treatment, understand available elections and plan for the U.S. tax consequences of their operations, ownership and transactions.

Entity Choice & Classification
- Entity Selection: Compare the U.S. tax treatment of corporations, partnerships and disregarded entities.
- Check-the-Box Elections: Assess Form 8832 elections and their potential tax consequences.
- Late-Election Relief: Review available options when an entity classification election was not made on time.
- Hybrid Mismatches: Address differences between U.S. and foreign tax treatment, including U.S. LLCs owned by foreign residents.
Review Your Structure
Foreign Company & Shareholder Planning
- CFC Planning: Assess controlled foreign corporation status and applicable U.S. reporting requirements.
- GILTI & Subpart F: Evaluate potential U.S. taxation of foreign company earnings, including amounts not distributed to shareholders.
- Section 962 Elections: Model the potential benefits and consequences for eligible individual U.S. shareholders.
- Foreign Tax Considerations: Review applicable high-tax exceptions and foreign tax credit implications.
Model Your GILTI Exposure
U.S. Market Entry & International Tax
- U.S. Market Entry: Compare branch, LLC and subsidiary structures before establishing U.S. operations.
- Tax Treaty & Withholding: Assess treaty provisions, withholding obligations and documentation requirements.
- Branch Profits Tax: Review potential branch profits tax exposure for foreign corporations operating in the United States.
- Double Taxation: Consider foreign tax credits, treaty relief and other applicable provisions.
- Multi-State Tax Exposure: Assess state filing obligations, income allocation and apportionment based on business activities.
Plan Your U.S. Entry
Owners, Exits & Transactions
- Profit Repatriation: Review the U.S. tax treatment of dividends, salaries and other payments to owners.
- Business Sales & Reorganizations: Assess U.S. tax consequences of sales, restructurings and business wind-downs.
- Transfers to Foreign Corporations: Review tax implications and reporting requirements for transfers of property or other assets.
- Owner-Level Tax Impact: Consider how business transactions affect the U.S. tax position of owners and shareholders.
Discuss a Transaction

Tax Compliance & Filing

U.S. tax returns and international reporting for businesses, partnerships, foreign corporations and foreign-owned U.S. entities. We handle income, ownership and related-party reporting, as well as specialized disclosures and catch-up filings where required.

U.S. Corporation & Partnership Returns

Federal and applicable state income tax returns, partnership reporting, and international schedules based on the entity’s activities and ownership.
- Form 1120 U.S. Corporation Income Tax Return
- Form 1120-S U.S. Income Tax Return for an S Corporation
- Form 1065 U.S. Return of Partnership Income
- Schedules K-2 and K-3 International tax reporting for partnerships and S corporations, where applicable
Start an Entity Return
Foreign-Owned U.S. Entities

Reporting for foreign-owned U.S. entities, including related-party transactions and applicable capital contributions or distributions. Filing requirements may apply even when an entity has little or no income.
- Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business
- Pro forma Form 1120 For applicable foreign-owned U.S. disregarded entities
- Form 1120-F U.S. Income Tax Return of a Foreign Corporation
Check Your Form 5472 Obligation
U.S. Owners of Foreign Companies

Reporting for U.S. shareholders of foreign corporations, including applicable ownership disclosures, CFC calculations, elections and property transfers.
- Form 5471 Certain Foreign Corporations
- Form 8992 U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI)
- Form 8993 Section 250 Deduction
- Form 926 Transfers of Property to a Foreign Corporation
Check Your Form 5471 Category
Foreign Partnerships & Other International Reporting

International reporting for foreign partnerships, foreign branches and disregarded entities, together with entity classification elections and available late-election relief.
- Form 8865 Certain Foreign Partnerships
- Form 8858 Foreign Disregarded Entities and Foreign Branches
- Form 8832 Entity Classification Election
Ask About Your Filing
Business Formation & Tax Identification

Assistance with EIN applications and initial U.S. tax registration requirements for eligible businesses and foreign owners.
- Form SS-4 Application for Employer Identification Number (EIN)
Ask About an EIN
Catch-Up Filings & Reporting Review

Review of prior-year U.S. returns and international information filings to identify outstanding obligations, address missed disclosures and determine the appropriate corrective steps.
Review Your Filing History

The forms and filing requirements depend on the entity’s classification, ownership, activities and specific circumstances.

Where Are You Based?

Where a company is formed, and where its owners live, change the U.S. filings the structure triggers.

Choose your location to explore the tax considerations relevant to you.

FAQ

Businesses & entities: common questions

I am a U.S. citizen who owns a company abroad. Do I have U.S. filing obligations?

Bottom line Owning a foreign company can create U.S. reporting and tax obligations even when the company does not distribute its profits.

Often, yes. U.S. persons who meet the applicable ownership and control thresholds for a foreign corporation may have to file Form 5471 with their U.S. tax return. Depending on the company’s ownership and income, the GILTI and Subpart F rules may also cause certain foreign earnings to be included in the U.S. shareholder’s income even when no dividend is paid. Form 5471 also carries significant penalties for missed filings.

I am a non-U.S. person with a U.S. LLC. Do I have to file if the LLC had no income?

Bottom line A foreign-owned U.S. LLC may have a Form 5472 filing obligation even when it had no income.

A foreign-owned single-member U.S. LLC that is treated as a disregarded entity for U.S. tax purposes may have a Form 5472 filing obligation, generally filed with a pro forma Form 1120. Reportable transactions can include transactions with the foreign owner, such as certain capital contributions and distributions. The filing requirement is not based simply on whether the LLC earned income during the year, and missed Form 5472 filings can carry significant penalties.

What is a “check-the-box” election?

Bottom line Entity classification is a planning decision that can affect the U.S. tax treatment of the business and its owners.

A check-the-box election under Form 8832 allows an eligible entity to choose how it is classified for U.S. federal tax purposes, such as a corporation, partnership or disregarded entity. The classification can affect how the business and its owners are taxed and reported in the United States. Timing also matters, particularly when an entity is being established or reorganized.

Can you work with my local accountant?

Bottom line Your local accountant can handle the local side while we coordinate the U.S. tax position.

Yes. Your local accountant can handle the tax filings and accounting requirements in your home country while we handle the U.S. tax and reporting requirements. We can coordinate the relevant financial information, elections and tax positions so that the U.S. and local filings are consistent.

My company is in Hong Kong or Singapore and pays little local tax. Does that change my U.S. position?

Bottom line Low local tax does not necessarily mean low U.S. tax, so the foreign company’s income and tax position should be modelled together with the U.S. owner’s position.

It can. A lower local tax burden does not necessarily reduce the U.S. tax consequences for a U.S. owner of a foreign company. Depending on the company’s ownership and income, GILTI or Subpart F may apply even when profits are retained rather than distributed. The Section 962 election and applicable high-tax rules may affect the result, but their availability and benefit depend on the company’s income and the foreign taxes actually paid or accrued.