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Advice for US citizens setting up a business in the UK

Due to the complex cross-border tax legislation between the US and UK, there is no one size fits all solution, and there are many variables to consider before making any decisions.

Last updated: 16 March 2020

In this video, Paul Baker and Meera Shah highlight the key considerations for US citizens looking to set up a business in the UK. Take a look at the Stepping Stones article below for more information, including a case study on how the process works in practice.

If you're a US shareholder of a controlled corporation (CFC), meaning you own more than 50% of the total value or combined voting power of a company based outside of the US, you should be aware of Global Intangible Low Taxed Income (GILTI) - take a look at this article for more information.

The impact of GILTI
You might also be interested in… Stepping Stones: US citizens setting up a UK business

When thinking about setting up a UK company, there is no one size fits all solution, and of course there are many variables to consider before making any decisions. If you have already established a UK company, it would be wise to consider how the 2018 tax reforms impact your global tax bill and whether an alternative type of business structure would be preferable.

Without careful consideration and advice, the complexity of US/UK cross-border tax rules could see more of your hard-earned money go straight to the pockets of the taxman! 

The case study below includes examples of how we helped our client, which includes advice on four key areas of US tax:

  • Form 8832 is the entity classification election, known as the 'check-the-box' election
  • Controlled Foreign Corporation (CFC) rules, including, Subpart F anti-avoidance rules
  • Passive Foreign Investment Company (PFIC) rules and tax treatment
  • Global Intangible Low Taxed Income (GILTI)

About the author

Paul Baker

+44 (0)20 7556 1391
bakerp@Buzzacott.co.uk
LinkedIn

When thinking about setting up a UK company, there is no one size fits all solution, and of course there are many variables to consider before making any decisions. If you have already established a UK company, it would be wise to consider how the 2018 tax reforms impact your global tax bill and whether an alternative type of business structure would be preferable.

Without careful consideration and advice, the complexity of US/UK cross-border tax rules could see more of your hard-earned money go straight to the pockets of the taxman! 

The case study below includes examples of how we helped our client, which includes advice on four key areas of US tax:

  • Form 8832 is the entity classification election, known as the 'check-the-box' election
  • Controlled Foreign Corporation (CFC) rules, including, Subpart F anti-avoidance rules
  • Passive Foreign Investment Company (PFIC) rules and tax treatment
  • Global Intangible Low Taxed Income (GILTI)

Read more…

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If you're a US citizen looking to set up a business in the UK, or if you are already the owner of a controlled foreign corporation (CFC), fill out the form below and one of experts will be in touch to answer your questions or provide advice tailored to you.

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Related links
Buzzacott_expatriate_tax Expatriate tax 1 Stepping Stones: US citizens setting up a UK business
When thinking about setting up a UK company, there is no one size fits all solution.… Read more Paul Baker
Associate Director 3 Stepping Stones 4 Meera Shah
Senior Manager (Corporate Finance) 5 Contact us 6
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