Services · Businesses & Entities
Cross-border structures, correctly reported
Foreign companies owned by Americans. US companies owned by foreigners. Partnerships that span both. The international entity rules are where US tax penalties are steepest — and where specialist preparation earns its keep.
US corporation returns
- Form 1120
- Form 1120-S
- State returns
Federal and state income tax returns for US C corporations and S corporations — including those with foreign shareholders, foreign operations, or cross-border transactions that bring the international reporting rules into play.
Partnership returns
- Form 1065
- Schedules K-2 / K-3
US partnership and multi-member LLC returns, with particular depth in the international schedules: foreign partners, withholding under sections 1446(a) and 1446(f), and the K-2/K-3 reporting that now accompanies almost any partnership with cross-border facts.
US owners of foreign corporations
- Form 5471
- GILTI — Form 8992
- Form 8993
- Form 926
When a US person owns enough of a non-US company, the company's books effectively become part of the owner's US filing. We prepare Form 5471 in all its categories, run the GILTI and Subpart F calculations, and advise on elections — such as section 962 — that can materially change the outcome.
This is a core specialism of the firm, particularly for owner-managed companies in Canada, Hong Kong and across Asia.
Foreign-owned US entities
- Form 5472
- Pro forma 1120
- Form 1120-F
Non-US persons investing into the US — a Delaware LLC, a US subsidiary, US real estate held through an entity — face their own reporting stack. We handle Form 5472 disclosure of related-party transactions, returns for foreign corporations with US business (Form 1120-F), and the withholding questions that follow the money.
Foreign partnerships
- Form 8865
US persons with interests in non-US partnerships may need Form 8865 — a filing comparable to Form 5471 in scope and in penalty exposure. We determine the filing category and prepare the return alongside your Form 1040 or entity filings.
Entity classification planning
- Form 8832
- Late-election relief
How an entity is classified for US purposes — corporation, partnership or disregarded — drives everything downstream. We advise on check-the-box elections when structures are set up or reorganised, prepare Form 8832, and pursue late-election relief where a deadline has already passed.
FAQ
Businesses & entities — common questions
I am a US citizen who owns a company in Canada or Hong Kong. Does the IRS care?
Very much so. US persons with sufficient ownership in a foreign corporation generally must file Form 5471 with their US return, and the GILTI and Subpart F regimes can tax the company’s earnings to you personally even if nothing is distributed. Missing the filing carries an automatic penalty starting at US$10,000 per form, per year.
I am a non-US person with a US LLC. Do I have US filings even if the LLC made no money?
Usually yes. A foreign-owned single-member US LLC must generally file Form 5472 attached to a pro forma Form 1120 each year to report transactions with its owner — including simple capital contributions. The penalty for not filing is US$25,000. Activity or profit is not required to trigger the obligation.
What is a “check-the-box” election?
Form 8832 lets many entities choose how they are classified for US tax purposes — corporation, partnership or disregarded entity. The election can dramatically change how a cross-border structure is taxed, and the deadlines and consequences are easy to get wrong. We advise on whether an election helps and prepare it when it does.
Can you work with my local accountant?
Yes — and it usually produces the best result. Your Canadian, Hong Kong or other local accountant handles local filings; we handle the US side and coordinate so positions, elections and financial statements line up across both returns.
Work with us
Own a company on either side of a border?
Send us the outline of your structure. We will identify the US filings it triggers and quote a defined scope before any work begins.