The U.S. Tax System Does Not Work Like Yours
Entity classification, withholding rules, treaty elections, estate tax exposure on U.S. assets. The rules are different and the penalties for getting them wrong are severe. Foreign investors who enter the U.S. without the right structure don’t find out until they’re in front of the IRS. Form 5472 is required for every reportable transaction between a foreign-owned entity and its related parties. The penalty for filing late or incomplete is $25,000 per form per year. The businesses that enter the U.S. successfully are the ones that build the structure before the first dollar moves.What We Handle
We work with foreign-owned U.S. subsidiaries, single-member LLCs owned by non-resident aliens, and inbound investment structures across real estate, private equity, and operating businesses:
- U.S. entity formation and structure analysis
- Form 5472 and related-party disclosure compliance
- FIRPTA withholding and compliance
- Tax treaty election and analysis
- ECI and FDAP income planning
- U.S. estate tax exposure for non-residents
- Inbound investment structuring
- EIN and ITIN applications for foreign owners
From Entry Through Ongoing Operations
We handle the initial structure and stay involved through ongoing compliance. Annual filings, related-party reporting, treaty positions, and U.S. tax return obligations. If you’re already operating without proper structure, we clean it up and get you properly documented. Your exposure in the U.S. is manageable when the right framework is in place from the start.What We Handle
- U.S. Subsidiaries & Branch Operations
- Foreign-Owned SMLLCs & Disregarded Entities
- Form 5472 & Related-Party Disclosures
- FIRPTA Compliance & Withholding
- Inbound Investment Structuring
- Tax Treaty Election & Analysis
- ECI & FDAP Income Planning
- U.S. Estate Tax Exposure for Non-Residents
- EIN & ITIN Applications
- U.S. Entity Formation (Florida, Wyoming, Texas)