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Corporate Tax

U.S. corporate tax, built for international businesses

Federal, state, and cross-border corporate tax expertise, coordinated by one team.

Talk to a Tax Advisor
  • U.S. Federal & Multistate Returns

    U.S. Federal & Multistate Returns

    Federal, state, and local filings handled end-to-end — deadlines, returns, and IRS notices managed in one place.
  • Cross-Border Structuring & Setup

    Cross-Border Structuring & Setup

    Pick the right entity — LLC, C-Corp, subsidiary, or branch — for tax efficiency, liability, and long-term growth.
  • International Tax Planning

    International Tax Planning

    Coordinate intercompany flows, apply treaty benefits, and avoid double taxation across jurisdictions.
  • Form 5472 & Foreign Ownership Reporting

    Form 5472 & Foreign Ownership Reporting

    Stay ahead of $25,000-per-party IRS penalties with complete, accurate annual disclosures.
Why it matters

U.S. tax is the most expensive thing you can guess at.

Foreign-owned businesses face a tax system layered across federal, state, and local jurisdictions — each with its own filings, deadlines, and penalty regimes. Cross-border tax issues require a clear understanding of both U.S. obligations and the expectations of international parent companies. This is where our specialization makes a difference.
Our team works with international operators entering, growing, or restructuring in the U.S. We translate U.S. rules into decisions your board can act on, and we sit between you and the IRS so you can focus on running the business.
Per-party IRS penalty for a missed Form 5472
$25K
U.S. local sales-tax jurisdictions to track
10,000+
Federal corporate rate — before state stacks on
21%
State filing regimes, each with their own rules
50
FAQ

Frequently asked questions

U.S. corporate tax works differently than most international businesses expect. Here are the questions we hear most from foreign-owned companies.

  • The U.S. federal corporate income tax rate is a flat 21%. It applies to the taxable income of U.S. C corporations, including U.S. subsidiaries owned by foreign companies. A foreign corporation operating directly in the U.S. (for example, through a branch) pays the same 21% rate on its effectively connected income (ECI) and may also owe the branch profits tax. This is only the federal rate: state corporate income taxes, franchise taxes, and local taxes can apply on top, depending on where the company operates.

  • The IRS determines U.S. tax liability for foreign corporations based on whether they have Effectively Connected Income (ECI) — income that is connected to a U.S. trade or business — or FDAP income (Fixed, Determinable, Annual, or Periodical) sourced from the U.S.

  • Unlike some jurisdictions, the U.S. does not require a formal fiscal representative. However, foreign companies with U.S. operations typically engage a U.S.-based tax advisor or CPA firm to handle filings, respond to IRS notices, and manage compliance obligations.

  • The penalty for failing to file Form 5472 (required for U.S. corporations that are at least 25% foreign-owned, and for foreign-owned single-member LLCs, that have reportable related-party transactions) is $25,000 per violation, per tax year. If the failure continues for more than 90 days after the IRS mails a notice, an additional $25,000 penalty applies for each 30-day period (or part of one) that it continues.

  • Economic nexus means a business can be required to register, collect, and remit sales tax in a state once its sales into that state pass the state’s threshold, even without a physical presence there. The most common threshold is $100,000 in annual sales, but some states set higher amounts, and many have dropped the old 200-transaction test, so each state’s rule needs to be checked. SaaS taxability also varies by state — some tax it fully, others partially, and some not at all.

  • For calendar-year C corporations, estimated tax payments are due on April 15, June 15, September 15, and December 15. Foreign corporations with U.S. operations follow the same schedule for ECI-related taxes.

  • Delaware corporations, including those owned by foreign shareholders, must file their annual report and pay their franchise tax by March 1 each year. The Authorized Shares method or Assumed Par Value Capital method can be used — the latter often results in significantly lower taxes for companies with high authorized share counts but low actual asset values. Delaware LLCs and LPs follow a different rule: they pay a flat annual tax by June 1 and do not file an annual report. Corporations formed outside Delaware and registered to do business there file their annual report by June 30.

  • Key obligations generally include: filing Form 1120 (federal corporate income tax return); Form 5472 if the subsidiary is at least 25% foreign-owned and had reportable transactions with related parties during the year (a single-member LLC wholly owned by a foreign company files it with a pro forma Form 1120); state income and franchise tax returns where the company is subject to them; payroll tax filings if it has employees; and sales tax registration in states where it has a physical presence or exceeds economic nexus thresholds.

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