Who this is for
- US shareholders of UK Ltd companies
- US persons acquiring or disposing of foreign corp shares
Entity & Partnership
Foreign corporations (Form 5471)
Required for US persons who own, control, or have changed their ownership in a foreign corporation — including UK Ltd companies.
Overview
Why this filing matters
Required for US persons who own, control, or have changed their ownership in a foreign corporation — including UK Ltd companies.
Note — UK Ltd companies with US owners.
What you get
- Category determination (1–5)
- Form 5471 preparation with required schedules
- GILTI / Subpart F analysis
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
Our process
How we handle your foreign corporations (form 5471)
Four steps from first call to filed return. Fixed fee confirmed before any work begins.
- 01
Intake
30-minute scoping call. We confirm your situation, required filings, and send a tailored document list.
- 02
Review
We analyse your position, flag any cross-border risks, and confirm the scope and fee before any work starts.
- 03
Prepare
Draft returns and schedules are prepared with plain-English commentary on key positions for your review.
- 04
File
E-file with the IRS / FinCEN, send confirmations, and handle any follow-up notices or questions.
Pricing
Fixed fees — no surprises
Form 5471: from £800 + VAT for a single Category 4/5 filing. GILTI computation, Section 962 elections, Subpart F analysis, and multi-category filings are priced after scoping.
FAQs
Common questions about Foreign corporations (Form 5471)
What makes me a Category 1–5 filer?
Roughly: Cat 1 (>50% owner of a specified foreign corporation), Cat 2 (US officer/director in an acquisition year), Cat 3 (acquisition/disposition crossing 10%), Cat 4 (control = >50%), Cat 5 (10%+ shareholder of a CFC). Required schedules differ by category.
Is my UK Ltd subject to GILTI?
If it's a CFC (generally >50% US ownership), yes — GILTI sweeps its 'tested income' into your US return annually, taxed at effective rates that can exceed UK corporation tax. A Section 962 election can mitigate by accessing corporate rates + FTCs.
Can my UK Ltd check-the-box?
Yes — electing transparent (partnership or disregarded) treatment avoids CFC and GILTI mechanics. Requires careful modelling of UK corporation tax vs US pass-through taxation; not always beneficial.
What's the penalty for missing 5471?
$10,000 per form per year initially, escalating by $10k for continued non-compliance up to $60k per form. One of the most aggressively enforced information returns. Catch-up options exist but are case-specific.
Do I file 5471 if I'm no longer a shareholder?
Category 3 covers dispositions, so yes — the year you exit typically still triggers a filing for that year. Don't skip it just because you've sold.
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.