U.S. ENTITY STRUCTURING & CROSS-BORDER PLANNING

Build a Business Structure Designed for Long-Term Growth

Align ownership, tax strategy, operational structure, and long-term planning through a more coordinated cross-border structuring approach designed to support scalability and reduce unnecessary complexity.

Request an Entity Structuring Consultation

WHY STRUCTURE MATTERS

Structure Matters More Than Most Businesses Realize

Whether you're entering the U.S. market, scaling operations, or managing multiple entities across jurisdictions, your business structure directly impacts tax exposure, compliance complexity, and long-term flexibility.

Without the right structure in place, businesses often:

Overpay in U.S. and cross-border taxes

Create unnecessary compliance and reporting burdens

Limit their ability to scale or restructure later

Make decisions without understanding structural implications

We work with businesses at critical points — formation, expansion, and restructuring — to ensure entity structures supports how the business actually operates.

Entity Structuring Support

No matter where your business stands today, your entity structure should support how you operate, grow, and plan ahead.
We work with businesses at different stages to ensure their structure is aligned, efficient, and built to support long-term outcomes.

New Entity Structuring
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Start with the right foundation from day one.

We help you:

Choose the appropriate entity type (LLC, C-Corp, S-Corp, partnership, etc.)
Evaluate ownership structure across jurisdictions
Understand tax implications at both business and owner levels
Align structure with funding, growth, and exit considerations

Entity Restructuring & Optimization

As your business evolves, your structure should too.

We help you:

Evaluate whether your current structure is still optimal
Identify inefficiencies or unnecessary tax exposure
Restructure entities to better align with operations and strategy
Simplify complex or multi-entity setups where possible

Cross-Border Structuring Strategy

Structure matters even more across jurisdictions.

We help you:

Navigate U.S. vs non-U.S. entity considerations
Align international structures
Minimize double taxation and reporting inefficiencies
Coordinate with legal and international advisors

Reduce Tax Exposure

Lower U.S. and cross-border tax risk through strategic structuring.

Align Business Strategy

Connect ownership, operations, and tax planning effectively.

Scale With Confidence

Build a structure designed for long-term business growth.

Find answers to frequently asked questions about our services and international taxes.

We are selling our product from our U.S. company to customers located outside the U.S. What are the tax implications?

This income is included on your U.S. tax return. It’s also possible that this income is taxable in the foreign country. You would need to determine the tax implications with your tax professionals in the U.S. and abroad. If there is an income tax liability in the foreign country, then you may be able to obtain a foreign tax credit on the U.S. return to avoid double taxation.

Can I form a corporation in the foreign country to avoid paying the higher U.S. tax liability on this foreign income or at least defer the tax until the income is repatriated at a later date?

Possibly. However, there may be anti-tax deferral provisions such as Global Intangible Low-Taxed Income (GILTI) that could apply that cause you to pay current tax on this non-U.S. income. You should seek tax advice to avoid onerous tax provisions.

Does GILTI apply to partnerships or pass-through entities?

No. GILTI applies to corporations who would otherwise be able to defer U.S. corporate income tax until a dividend is paid. Income from the partnerships or pass-through entities is includable on the U.S. company return in the year it is earned.

What is the U.S. tax on repatriated dividends from foreign affiliates?

Under current law, there is no tax since the U.S. corporation would obtain a 100% dividend deduction.

Are there U.S. tax incentives for a U.S. company with foreign sales?

Yes. U.S. corporations benefit from tax incentives such as deducting a portion of foreign-derived intangible income (FDII), linked to intangible assets held domestically. Additionally, the Interest Charge Domestic International Sales Corporation (IC-DISC) provides substantial tax savings for exporting U.S. products. Unlike tax shelters, IC-DISC facilitates permanent tax savings by transferring income through export sales commissions.

OUR PROCESS

01

Assess
‍Review ownership, operations, structure, and long-term business goals.
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02

Design
‍Build a structure aligned with tax strategy, scalability, and operational flexibility.

03

Coordinate
‍Work alongside legal and advisory teams to support implementation and alignment.
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04

Support
‍Continue refining structure as operations and complexity evolve.

CLIENT TESTIMONIAL

Trusted by Business Owners Navigating Complex U.S. Tax

"I first found Lodder CPA when my current U.S. accountant was not filing my taxes properly. I also reached out to Lodder CPA to help me get caught up on previous years that were not filed as well as to help my through my renunciation process. I am a U.S. citizen living in Canada and I also own a business. Lodder CPA not only helped me get caught up on four years of taxes but they also helped guide me through the renunciation process. Lodder CPA was efficient, accurate and extremely helpful. You have peace of mind knowing they are handling your taxes even if your situation is extremely complex. Whether you are a company, individual or a U.S. citizen living abroad I couldn't have found a better accountant. I recommend 10/10."

Carrie Ball
RE/MAX Truepeak Realty

"When we were looking to open up business in the USA, Lodder CPA was highly recommended by our Canadian CPA as a Company we could trust to ensure that our business would be setup correctly for US Taxes and protected. Kyle has been fantastic to work with and his connections have been invaluable in getting incorporated in the USA quickly, professionally and in compliance with the US legal system. Highly recommend!"

Alex Fortin
President