Entity & Partnership

Disregarded entities (Form 8858)

UK LLPs and sole-trader structures are typically disregarded for US tax purposes and must be reported annually.

Entity & Partnership
Overview

Why this filing matters

UK LLPs and sole-trader structures are typically disregarded for US tax purposes and must be reported annually.

Note — UK LLPs, sole trader structures.

Who this is for

  • US owners of UK LLPs
  • US sole traders operating in the UK

What you get

  • Form 8858 preparation
  • Currency & transfer pricing review
Our approach

Built for the cross-border edge cases.

Most US-UK filings fail the same way: a treaty position that wasn’t disclosed, a foreign account that slipped under FBAR thresholds, a PFIC election filed in the wrong year, a carry-forward not tracked from one preparer to the next. The cost of any single one of those is rarely catastrophic on its own — it’s the compounding over multiple filing seasons that quietly turns a clean tax life into a six-figure remediation project.

We start every engagement by looking at the edge cases first — the elections, the disclosures, the carry-forwards, the side-effects on next year’s return — and only then turn to the routine line items. The result is a filing that reads cleanly to anyone who picks it up next: another preparer, the IRS, or a successor in your own business.

  • Position memo on every meaningful election, with the reasoning written down for the next return
  • Carry-forwards (FTC, capital losses, PFIC basis) tracked year-on-year so nothing expires unused
  • Plain-English commentary on every position taken — the kind that makes a future audit a non-event
Reviewing UK company shareholdings for US disclosure
Our process

How we handle your disregarded entities (form 8858)

Four steps from first call to filed return. Fixed fee confirmed before any work begins.

  1. 01

    Intake

    30-minute scoping call. We confirm your situation, required filings, and send a tailored document list.

  2. 02

    Review

    We analyse your position, flag any cross-border risks, and confirm the scope and fee before any work starts.

  3. 03

    Prepare

    Draft returns and schedules are prepared with plain-English commentary on key positions for your review.

  4. 04

    File

    E-file with the IRS / FinCEN, send confirmations, and handle any follow-up notices or questions.

Pricing

Fixed fees — no surprises

Form 8858 preparation starts from £400 + VAT per entity. Classification reviews and check-the-box elections (Form 8832) are priced separately.

FAQs

Common questions about Disregarded entities (Form 8858)

Why is my UK LLP a disregarded entity?
Default US classification for single-owner foreign unlimited-liability entities (like UK LLPs with one US member). Treated as part of the owner for US tax purposes — income and deductions flow directly to your 1040.
Can I elect corporate treatment instead?
Yes — Form 8832 'check-the-box' lets you elect to be taxed as a corporation (CFC). We model whether it helps your overall position before filing the election; it's not always beneficial.
Do I still pay UK tax on LLP income?
UK rules are separate. Most UK LLPs are transparent for UK tax too, so the income flows through to the members under UK self-assessment. The US treatment mirrors this by default.
Is 8858 enough or do I need 5471 / 8865 too?
Depends on structure. Single-member foreign disregarded entity is 8858 only; multi-member partnership is 8865; elected corporation is 5471. We confirm classification at intake.

Ready to get this filed?

Tell us your situation and we'll confirm scope, a fixed fee, and the documents we need — usually within one business day.