Business Taxation Services
Operating a U.S. business while living abroad introduces layers of complexity that demand specialized expertise. From foreign-owned single-member LLCs to international partnerships, we provide comprehensive tax solutions that ensure compliance while optimizing your global tax position.
The U.S. tax code's treatment of business entities becomes exponentially more complex when international elements are introduced. Whether you're a U.S. citizen running a business from abroad, a foreign national investing in U.S. enterprises, or managing cross-border partnerships, the intersection of entity taxation, international reporting requirements, and treaty considerations requires careful navigation. Our specialized business tax services address the unique challenges faced by international entrepreneurs, ensuring your business structure supports your goals while maintaining full compliance with U.S. tax obligations.
Critical Consideration: The choice of business entity has profound implications for international tax planning, affecting everything from withholding requirements to treaty eligibility and exit strategies. Making the right choice from the start can save substantial taxes and compliance costs down the road.
Single-Member LLC Taxation
For international entrepreneurs, the single-member LLC presents unique opportunities and obligations. While these entities are typically disregarded for U.S. income tax purposes, foreign ownership triggers specific reporting requirements that many business owners overlook—often resulting in devastating penalties. The interplay between the LLC's tax transparency and international reporting obligations creates a compliance landscape that demands specialized attention.
Our single-member LLC services encompass:
- Form 5472 Compliance: Accurate reporting of all reportable transactions between the foreign owner and the LLC, with meticulous documentation to avoid the $25,000 per form penalty
- EIN Procurement and Banking Support: Assistance with obtaining federal tax identification numbers and navigating U.S. banking requirements for foreign-owned entities
- State Tax Coordination: Managing state-level filing obligations, including franchise taxes and annual reports across multiple jurisdictions
- Treaty Optimization: Structuring operations to maximize treaty benefits while maintaining the LLC's tax efficiency
- Exit Planning: Strategic guidance for eventual sale or dissolution with minimal tax impact
We understand that foreign-owned LLCs face unique challenges, from banking restrictions to withholding requirements on U.S.-source income. Our comprehensive approach ensures your LLC operates efficiently while meeting all compliance obligations, protecting you from penalties that often exceed the business's annual revenue.
Optimize Your LLC Structure →Corporation Taxation
U.S. corporations owned or operated by expatriates and foreign nationals navigate a complex web of domestic and international tax rules. The Tax Cuts and Jobs Act's international provisions, including GILTI, FDII, and BEAT, have fundamentally altered the landscape for internationally-focused corporations. Whether you're operating a C-corporation or have elected S-corporation status (where eligible), proper tax planning and compliance are essential to avoid double taxation and optimize your global tax position.
Our comprehensive corporation tax services include:
- Entity Selection and Formation: Strategic analysis of C-corp versus S-corp benefits in the international context, including treaty eligibility considerations
- International Tax Planning: Navigation of Subpart F, GILTI, and participation exemption rules for optimal tax efficiency
- Transfer Pricing Documentation: Establishing and documenting arm's length pricing for intercompany transactions
- Form 5471 and 5472 Reporting: Accurate preparation of information returns for foreign shareholders and related-party transactions
- Withholding Tax Management: Minimizing withholding on dividends, royalties, and other payments through treaty planning
- State and Local Tax Strategy: Multi-state tax planning and compliance for corporations with national or international operations
We recognize that international corporations face pressure from multiple tax jurisdictions. Our expertise in both U.S. corporate taxation and international tax treaties enables us to develop structures that minimize global tax liability while ensuring full compliance with increasingly aggressive reporting requirements.
Structure for Global Success →Partnership Taxation
International partnerships represent one of the most complex areas of U.S. taxation, where the already intricate rules of Subchapter K intersect with international reporting requirements and withholding obligations. Whether you're a foreign partner in a U.S. partnership or managing a partnership with international operations, the compliance burden can be overwhelming. Recent regulatory changes have intensified scrutiny on partnership allocations and international transactions, making expert guidance more critical than ever.
Our partnership taxation services address:
- Partnership Agreement Structuring: Drafting tax provisions that optimize allocations while satisfying substantial economic effect requirements
- Foreign Partner Withholding: Managing complex withholding requirements under Sections 1441 and 1446, including quarterly deposits and annual reconciliations
- Form 8865 Reporting: Comprehensive reporting for U.S. persons with interests in foreign partnerships, including Schedule K-3 preparation
- Effectively Connected Income Planning: Structuring partnership operations to minimize ECI exposure for foreign partners
- FIRPTA Compliance: Managing withholding obligations on dispositions of U.S. real property interests by partnerships
- State Tax Considerations: Navigating composite returns and withholding requirements across multiple state jurisdictions
Recent Development: The IRS has dramatically increased enforcement of foreign partner withholding requirements, with penalties for non-compliance reaching 37% of distributions. Proper structuring and compliance are no longer optional—they're essential for partnership viability.
Our partnership tax team combines deep technical knowledge with practical experience in international transactions. We help partnerships balance the flexibility that makes them attractive with the compliance requirements that keep them viable, ensuring your partnership serves its business purpose without creating unnecessary tax exposure.
Navigate Partnership Complexity →