HubSpot Video

Many entrepreneurs find the US tax rules to be an impenetrable web of acronyms, jargon, and technical detail.

 

Our US UK Private Client team specialise in helping people like yourself to navigate the US and UK tax rules, cutting through the confusion, translating some of the key terms, and helping you understand how these rules affect your business.

 

We aim to provide practical advice and prepare your US tax return filings to ensure that you comply with the increased reporting required by the IRS for US entrepreneurs.

 

In the following short videos and accompanying articles we look at how these rules apply to a US citizen in the UK who owns a UK company.

If you would like to discuss how any of these rules relate to your business, please get in touch with your usual Blick Rothenberg contact or Alex or Michael using the form below.

Glossary of terms

 

Controlled Foreign Corporation (CFC)

A non-US company controlled by US persons

 

Subpart F Income

The CFC rules that affect passive income

 

Global Intangible Low Taxed Income (GILTI)

The CFC rules that affect active business income

 

Passive Foreign Investment Company (PFIC)

A non-US company that is not a CFC, but earns passive income

Controlled Foreign Corporations (CFCs)

HubSpot Video

Where the US tax rules have the biggest impact on entrepreneurs is if the US considers your interest in the UK company to be a Controlled Foreign Corporation, or CFC.

 

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Subpart F Income

HubSpot Video

Subpart F income is the US tax rule, designed to stop US taxpayers using non-US companies that have income from investments and any other passive sources. This can include interest, gains, rental and also catch certain personal service company income. Where a CFC has passive income, the US can tax the shareholder’s share of the income on them personally. This is Subpart F income.

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Global Intangible Low Taxed Income (GILTI)

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Global Intangible Low Taxed Income, or GILTI, was brought in as part of President Trump’s 2018 tax changes. Where previously, the Subpart F rules impacted CFCs with passive income, GILTI affects nonpassive income.

 

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Passive Foreign Investment Company (PFIC) Rules

HubSpot Video

If you are a US shareholder of your business, but the other non-US owners own the majority of the

company, it may not be a CFC. Instead, you need to look at the Passive Foreign Investment Company or PFIC rules.

 

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Links

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Controlled Foreign Corporations (CFCs)

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Subpart F Income

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Global Intangible Low Taxed Income (GILTI)

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Passive Foreign Investment Company (PFIC) Rules

Our expert team

RS743_Alex Straight - Partner 3-scr
Partner

Alex Straight

Michael Holland - Director
Director

Michael Holland

 

US/UK Private Client

Personal tax is one of the most complex areas of wealth management and can significantly erode your wealth over time.

Blick Rothenberg is considered to be market leaders in the taxation of non-UK domiciled individuals and offshore trusts, as well as cross-border personal taxation.

We have a strong base of clients in the UK and abroad and longstanding international focus too, acting for a large number of non-UK domiciled individuals and international families. We therefore understand the complexities that US citizens face when living, working and operating businesses in the UK.

Whether you are a start-up entrepreneur, a wealthy family with complex affairs, or a business executive, our dual-qualified team of tax advisers will look after your US UK personal tax affairs as well as those of your business.

If you wish us to contact you or want to discuss your situation please complete the form on this page and one of our team will be in touch.