Who we help
Founders & equity holders
Equity is where cross-border tax gets expensive, and most of the damage is done at grant rather than at exit.
The structure at incorporation decides what the exit costs.
Options, growth shares and founder equity are taxed on different triggers in each country, and the two rarely align on timing.
By the time there is a liquidity event, the position is largely fixed. The decisions worth having advice on happen years earlier.
What we handle
01
Equity across borders
Grant, vest, exercise and sale can each be a taxable moment, and not in the same country or the same year.
02
Scheme design
EMI options are efficient in the UK and can be awkward for US taxpayers. Worth knowing before the scheme is written.
03
Elections with deadlines
Some US elections are worth a great deal and expire within days of grant. Missing them is not recoverable.
04
Company reporting
Ownership of a non-US company brings Form 5471 and, potentially, the GILTI rules for US shareholders.
Why us
Advice that arrives before the term sheet
Most founder tax problems we see were created by an ordinary decision — where to incorporate, how to paper a grant — taken without anyone asking about the other country.
We would rather be a short conversation at formation than a long one at exit.
Frequently asked
I am a US citizen founding a UK company. What matters most?
How the company is classified for US purposes, whether Form 5471 and GILTI apply, and how your equity is structured. All three are far cheaper to get right at formation.
Are EMI options a problem?
They are excellent for UK taxpayers, and the US does not recognise the same treatment. It does not make them unusable — it makes the US side something to plan for rather than discover.
What is a Section 83(b) election?
An election to be taxed on restricted equity at grant rather than as it vests. It must be filed within 30 days of grant, and the deadline cannot be extended or cured.
Should I incorporate in the US or the UK?
It depends on where your customers, investors and you are. The tax answer is rarely decisive on its own, but it is much cheaper to consider before incorporation than after.
Do I file Form 5471 for my own company?
If you are a US person with sufficient ownership or control of a non-US company, generally yes — annually, whether or not it is profitable or has distributed anything.
How is an exit taxed across both countries?
Both may tax the same gain, with credit relief depending on residence and timing. Business Asset Disposal Relief in the UK has no US equivalent, so a UK-efficient exit can still carry full US tax.
When should I get advice?
Before incorporation, before any equity is granted, and before signing a term sheet. After those points the structure is largely fixed.
Equity is where cross-border tax gets expensive, and most of the damage is done at grant rather than at exit.
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