US tax compliance and planning for foreign-owned businesses and cross-border individuals, from the first Form 5472 to a full treaty position.
Cross-border tax is where the highest penalties live: $25,000 for a missed Form 5472, $10,000 or more per unfiled foreign information return, often on filings that produce no tax at all. It is also the corner of the code most US firms quietly avoid.
We work at that intersection daily: foreign owners of US entities, US persons with foreign companies and accounts, families relocating to the United States, and groups that need both sides of a structure understood, not just the US half.
In practice, that means information returns filed complete and on time, treaty positions taken with disclosure where required, and pre-arrival planning done before US residency starts the clock, because the cheapest cross-border problems are the ones prevented.
Form 5472 with pro forma 1120 for foreign-owned single-member LLCs, Form 1120-F for foreign corporations, and related withholding compliance.
FinCEN Form 114 and Form 8938, plus Forms 5471 and 8865 for US persons with interests in foreign companies, including catch-up filings where eligible.
Pre-arrival structuring, residency start-date planning, and dual-status returns for individuals moving to the United States.
Treaty-based positions with Form 8833 disclosure, W-8 series documentation, and withholding analysis for cross-border payments.
Everything a foreign founder needs to stand up a compliant US operation, from formation to first filing season.
Explore serviceFederal and state compliance handled end-to-end, accurate returns, defensible positions, and planning that happens before year-end, not after it.
Explore serviceWhen the IRS writes, you don't respond alone, representation under Circular 230, from first notice to resolution.
Explore service