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