U.S. International Tax · Tax Treaties · IRS Code
We help foreign companies form a U.S. subsidiary, structure it for the lowest treaty-aware tax, and run the finance and agency work after launch. We also handle U.S. returns for Americans living abroad.
Consultations in English & Korean · 영어·한국어 상담 가능
For foreign companies entering the U.S.
A Korean, UK, Australian, or New Zealand parent company opening a U.S. arm faces two systems at once. We set it up correctly the first time and stay on as your finance and compliance desk.
Entity choice, state of incorporation, EIN, registered agent, and the federal elections (incl. Form 5472 / treaty positions) that a foreign-owned company must get right from day one.
We don't file your forms and disappear. We sit in the founder's seat with you — cap table, books, and operating setup — so you can focus on the product, not the paperwork.
Bookkeeping, payroll, vendor payments, cash-flow runway, and board-ready reporting — the finance function a young company needs before a full-time hire makes sense.
We stand between you and the IRS, the Franchise Tax Board, the Secretary of State, and the EDD — a safe, correct setup on day one, and no costly miscommunication with agencies later.
The periodic filings that quietly lapse and trigger penalties: business-license and registration renewals, Statements of Information, registered-agent upkeep, and franchise-tax minimums — kept on a calendar we own.
Intercompany pricing, the parent's U.S. reporting exposure, withholding on dividends and royalties, and the treaty article that lowers each rate — coordinated with your home-country filing.
Which entity is right for a foreign owner?
A separate taxable entity. Pays 21% federal corporate tax; profits are taxed again when paid out as dividends. No limit on foreign shareholders, and it's the structure U.S. investors expect.
✓ Usual fit for a foreign parentPass-through — profit flows to owners and is taxed once. But every shareholder must be a U.S. citizen or resident; non-resident aliens and foreign companies cannot own an S-Corp.
✕ Not available to foreign ownersFlexible — pass-through by default, or it can elect corporate tax. A foreign-owned single-member LLC carries a Form 5472 duty and can pull the foreign owner into U.S. filing through effectively connected income.
~ Useful in specific casesFor most foreign companies opening a U.S. subsidiary, the C-Corp is the cleanest path — foreign ownership is unrestricted, the parent stays out of U.S. personal returns, and it's what investors expect. But the right answer turns on your ownership, funding plan, and home-country treaty. We model the tax outcome both ways before you sign the formation papers.
For Americans living abroad
U.S. citizens and green-card holders file no matter where they live. We keep you compliant and claim every exclusion, credit, and treaty position you're entitled to.
Foreign Earned Income Exclusion and Foreign Tax Credit, optimized so you don't pay twice on the same income.
Foreign account and asset reporting done right — the filings with the steepest penalties when they're missed.
Behind on filing? The Streamlined Foreign Offshore Procedures let many expats catch up penalty-free. We assess eligibility and prepare the package.
Totalization Agreement analysis so freelancers and founders aren't charged Social Security tax by two countries at once.
Own a foreign corporation, partnership, or pooled fund? Forms 5471, 8865, and 8621 (PFIC) handled — including mark-to-market and excess-distribution analysis.
State residency exits and non-resident returns (1040-NR) for foreign nationals with U.S.-source income — taxed only on what the treaty allows.
How a U.S. launch works with us
We map ownership, pick the entity and state, and model the tax both ways against your home-country treaty.
Incorporation, EIN, registered agent, bank-ready documents, and the federal elections a foreign-owned entity needs.
Fractional CFO from day one — books, payroll, vendor payments, and reporting your board and parent can read.
We hold the line with U.S. agencies and keep every recurring renewal and filing on schedule, year after year.
Treaties & the Internal Revenue Code
We don't guess at cross-border tax. We cite the specific treaty article and IRS Code section behind each position — so it holds up under examination.
Reduced rates on dividends, interest, and royalties between a U.S. sub and its foreign parent — claimed correctly so the lower treaty rate actually applies.
Whether your activity creates a U.S. taxable presence — the PE analysis that decides if the parent itself owes U.S. tax.
Foreign tax credit baskets and re-sourcing, so income taxed abroad isn't taxed again in the U.S. beyond what the Code allows.
After your consult we'll send a flat-fee quote. Pay securely by card to open your engagement — no U.S. bank account required.
Start the conversation
Tell us where your company or your filing stands. We'll map the situation, flag anything urgent, and give you a flat-fee quote before you commit to anything.
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