Running a UK and U.S. company?
Find out if your structure is actually right.
Most founders running a UK and a U.S. entity won’t know there’s a structural problem until HMRC or the IRS tells them, by which point it’s usually been building for several years.
Form 5472
Penalty
BE-13 Survey
Penalty (max)
Tax on LLC
Profits (UK & U.S.)
This
Consultation
Two companies. Two accountants. One gap that neither of them is covering.
Your UK accountant deals with HMRC, and your U.S. accountant deals with the IRS, which means the obligations that sit between the two jurisdictions aren’t really anyone’s job to flag. That’s not a criticism of either adviser; cross-border tax is a specialism, and most practitioners work within one system.
In Anson v HMRC, a UK resident with a U.S. LLC faced the prospect of an effective tax rate of around 67% on the same income because the U.S. and UK classified the entity differently. HMRC argued that no double-tax relief was available, and the dispute ultimately reached the UK Supreme Court, which ruled in Anson’s favour. The case is often cited as an example of the double-tax risks that can arise when HMRC and the IRS view the same entity differently.
“The founders who find out there’s a problem are the lucky ones. They find out before the exposure has had years to accumulate. The ones who don’t find out until HMRC raises an enquiry are the ones who wish they’d had this conversation earlier.”
Whether your structure has the same exposure depends on your specific setup. The call is thirty minutes, at no cost, and it’s the only way to know.
Thirty minutes to get a view of both sides that most founders have never had.
Whether the entity you’re running creates risk for a UK-resident owner, and what that risk looks like.
HMRC’s treatment of foreign entities doesn’t always align with the IRS’s. That difference has a cost.
Annual filings required for foreign-owned U.S. entities, and the penalties for missing them. Most UK founders aren’t aware of these.
The obligations that fall between your UK adviser and your U.S. one, and whether any of them apply to you.
What needs to be filed in both jurisdictions, by whom, and on what timeline, with full visibility of both sides.
You leave knowing exactly where your structure stands. Not a sales pitch. A clear view of your position.
This call is for UK founders who are already operating in both jurisdictions.
LLC or C-Corp, and you’re not fully confident the structure is right.
And you suspect, or know, that nobody has a joined-up view of your full position.
With the authority to make decisions about your structure and compliance.
The structure matters most when there’s real money moving through it, and real exposure if something isn’t right.