Founders & Entrepreneurs
Cross-border tax strategy for founders building in both markets: entity structure, CFC and GILTI planning, equity that works in two systems, and exits designed years in advance.
Two returns, one plan.
Building a company across the US and UK multiplies every tax decision. A US founder with a UK Ltd inherits CFC and GILTI rules; a UK founder raising in the US faces entity choice, flips, and QSBS. The structure you pick in year one determines what your exit looks like in year eight.
We advise founders from incorporation through sale, with company structure, personal returns, and equity coordinated by one team that sees both sides of the Atlantic.
How we help founders and entrepreneurs
Structure, compliance, and exit planning for companies that span two tax systems.
CFC & GILTI Planning
A US founder who controls a UK Ltd owns a controlled foreign corporation. We manage GILTI inclusions, Subpart F exposure, and Section 962 elections so the structure doesn't tax you on profits you never distributed.
Form 5471 Compliance
US persons with significant ownership in foreign companies must file Form 5471, one of the most complex forms in the code, with steep penalties for getting it wrong. We prepare it accurately every year, with the books to back it.
US Expansion Structuring
Delaware C-corp, US subsidiary, or flip? For UK founders entering the US market, entity choice drives investor access, double-tax exposure, and your eventual exit. We model the options before you incorporate.
Equity Across Borders
Options, RSUs, and founder shares are taxed differently on each side. EMI options lose their UK relief for US persons, and QSBS can be worth millions on exit. We structure grants so equity works in both systems.
Transfer Pricing & IP Location
Once you operate on both sides of the Atlantic, intercompany charges and IP ownership need defensible arm's-length positions. We set pricing and IP location early, when it's cheap to get right.
Exit & Sale Planning
A sale touches capital gains rules, QSBS, Business Asset Disposal Relief, and treaty sourcing in two countries at once. We plan the exit years ahead so the structure is ready when the offer arrives.
Get your company structure reviewed before your next raise, grant, or expansion locks it in.
Get StartedExplore our tax services
Structure choices are strategy choices.
The most expensive founder tax mistakes (the wrong entity, EMI granted to a US person, IP in the wrong company) are all made early and discovered late. We put cross-border eyes on the structure while it's still cheap to change.
Every raise and every grant is a tax decision.
Founders make structural tax choices constantly, usually without noticing: where to incorporate, who gets options, which entity holds the IP, when to flip. We sit on your side of those decisions so each one strengthens the exit instead of complicating it.
GILTI Modeling & 962 Elections
We calculate your GILTI exposure annually and elect Section 962 corporate treatment when it wins, which often cuts the effective rate dramatically.
Entity Choice by the Numbers
C-corp, Ltd, LLC, or a check-the-box hybrid: we model each structure against your investors, margins, and exit horizon before you commit.
Equity Grant Coordination
We check every grant against both systems (EMI qualification, 409A valuation, 83(b) timing, and QSBS eligibility) before paper is signed.
Exit Runway Planning
QSBS clocks, holding periods, and residence positions all reward advance planning. We build the exit structure years before the term sheet.
Why founders choose US/UK Cross Border Tax
Both Sides, One Team
US CPAs and UK tax advisers work the same structure, so your company, your equity, and your personal returns are planned as one system.
Founder-Stage Fluency
Incorporation, first hires, fundraises, flips, exits: we know which tax decisions matter at each stage and which can wait.
Structure Before Symptoms
Most cross-border founder tax problems are structural and cheapest to fix early. We design around GILTI, PFIC, and double-tax traps before they appear on a return.
Fixed, Transparent Pricing
Cross-border compliance shouldn't mean open-ended hourly billing. We give you a fixed quote up front that covers both jurisdictions.
"We were about to grant EMI options to our American CTO when they flagged the US-side problem. They restructured the grants, handled our 5471s, and modeled the Delaware flip so we walked into our Series A with a clean structure."
Founder Tax Questions
Common questions from founders building companies across the US and UK.
Two Tax Systems, One Team
Email Us
hello@usukcrossbordertax.comLondon Headquarters
4 Crown Place
London EC2A 4BT
United Kingdom
Manchester
CORE
Brown St, Manchester M2 1DH
United Kingdom
San Francisco
600 California St
San Francisco, CA 94108
United States
New York
33 Irving Pl
New York, NY 10003
United States