Services
Business & corporate tax
UK limited companies under US rules, GILTI, permanent establishment and expansion in either direction — structured before it gets expensive.
Structure it before it gets expensive.
A UK limited company with an American owner is a US tax event every year, whether or not it distributes anything.
Entity choice, permanent establishment and reporting are far cheaper to resolve before incorporation than after.
What we do
01
Entity selection
How the structure will be seen from both sides, including check-the-box elections and their consequences.
02
Controlled foreign corporations
Form 5471 reporting, GILTI computations and the elections that reduce the sting.
03
Permanent establishment
Whether activity in the other country creates a taxable presence, before it quietly does.
04
Owner remuneration
Salary and dividend mixes that work in both systems rather than optimising one at the other's expense.
Why us
Cheaper before incorporation
Most of the expensive outcomes we see began as a reasonable structuring decision that only considered one country.
An hour before you incorporate is worth more than a year of remediation afterwards.
When it comes to questions that cross two tax systems, you need specialists who work in both every day. Meet the team that make it happen.
View our peopleFrequently asked
I own a UK company and I am American. What do I file?
Generally Form 5471 each year, with GILTI potentially bringing profits into your US return whether or not you take a dividend.
Does a check-the-box election help?
Sometimes materially. It also has lasting consequences and can be hard to reverse, so it deserves modelling first.
What is a controlled foreign corporation?
Broadly a non-US company sufficiently owned by US shareholders, which brings anti-deferral rules including GILTI and annual Form 5471 reporting.
Should I use an LLC?
If you are UK-resident, usually not. HMRC's treatment of LLCs can produce double taxation without relief, and it is a common and costly default.
Do I need a US EIN?
If the company has US filing obligations, employees or certain US payments, generally yes. It is straightforward to obtain but takes time.
How are dividends taxed across both systems?
Both may tax the same distribution, with treaty rates and credit relief reducing the total. The order in which profits are extracted materially affects the outcome.
UK limited companies under US rules, GILTI, permanent establishment and expansion in either direction — structured before it gets expensive.
Key contact
Tell us what you are trying to solve and we will put the right specialist on the call.
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US–UK tax team
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Specialists who work in both tax systems every day, not one with a view on the other.