Guidance for INTERNATIONAL OPERATIONS & CROSS-BORDER COMPLEXITY

Scale Internationally Without Losing
Visibility or Control

Scale international operations through a more coordinated cross-border strategy designed to improve financial visibility, reduce unnecessary tax exposure, and support more scalable long-term international growth.

GLOBAL COMPLEXITY

As Your Business Expands, Complexity Becomes
Harder to Manage

Operating across borders introduces structural and tax complexity that builds over time. For many businesses,
it begins to show up in a few key ways:

Revenue generated across multiple countries
without a clear, unified tax strategy
Foreign entities or subsidiaries
established over time without a coordinated structure
Advisors in different jurisdictions
working independently, without full alignment
Growing uncertainty around tax exposure,
reporting requirements, and how profits should be handled

This affects profitability, risk, and how confidently the business can continue to grow.

HOW WE HELP

How We Support Your International Operations

Structured Entity Design

Reduce inefficiencies and support long-term scalability by aligning your entity structure with how your business operates across jurisdictions.

Cross-Border Tax Strategy

Improve tax efficiency and avoid unnecessary overpayments by identifying where tax is being lost and implementing strategies that maintain full compliance across jurisdictions.

Accounting Support and
Financial Visibility

Gain clear visibility into performance across your business through full cross-border bookkeeping and ongoing support tailored to the complexity of your operations.

Centralized Coordination

Operate with alignment across your entire advisory team by working through a single, coordinated strategy that connects your tax, financial, and operational decisions.

Clarity Across Your Structure

Know exactly how your business is structured, how money flows, and how decisions in one jurisdiction impact another

Reduced Tax Exposure

Eliminate unnecessary tax inefficiencies and ensure your structure is aligned to minimize risk and cost

Coordinated, Scalable Growth

Operate with a structure that supports expansion, with advisors aligned and strategy evolving as your business grows

Integrated Support for Growing
International Operations

Cross-Border Tax Strategy & Advisory

Navigate international tax exposure, reporting obligations, entity structure, and long-term cross-border planning through a more coordinated strategic approach.

Explore Tax & Advisory Services    

Accounting Review & Financial Visibility

Strengthen operational visibility, reporting alignment, and financial oversight across jurisdictions through structured accounting support and ongoing advisory guidance.

Explore Accounting Services    

Entity Structuring & Cross-Border Planning

Design a legal and operational structure that supports long-term growth, reduces unnecessary complexity, and aligns with your broader cross-border business strategy.

Explore Entity Structuring Services    
CLIENT TESTIMONIAL

Trusted By International Businesses Expanding into the U.S.

“PacificEast was becoming more complex in its cross-border and overall U.S. business. Lodder CPA has communicated well and provided the excellence PacificEast requires.”

Garth Froese
Chief Executive Officer

“Kyle’s expertise in accounting, particularly in complex tax laws related to cross-border business activities, is exceptional. He provides tailored solutions that make us feel confident about the long-term success of our business.”

Rob McWhinney
Founder and President

“Kyle’s expertise in accounting, particularly in complex tax laws related to cross-border business activities, is exceptional. He provides tailored solutions that make us feel confident about the long-term success of our business.”

Rob McWhinney
Founder and President

INTERNATIONAL REPORTING & CROSS-BORDER TAX COMPLEXITY

Built for Businesses Navigating Complex International Structures

Lodder CPA helps businesses navigate international structures and reporting requirements tied to:

  • Foreign corporation reporting (Form 5471)
  • Foreign partnership reporting (Form 8865)
  • Disregarded entity reporting (Form 8858)
  • Foreign tax credit planning
  • GILTI, NCTI, PFIC, and Subpart F exposure
  • Multi-entity international structures
  • Cross-border reporting coordination across jurisdictions
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FAQs

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.

CLIENT SUCCESS SNAPSHOT

See How We've Helped Businesses Move Forward with Confidence

My business is registered in the USA while I live in New Zealand, so getting the cross-border structure right was critical.

Dr. Brad Stanfield

OUTCOME

Saved tens of thousands of dollars annually through a more efficient cross-border tax strategy.

HOW WE HELPED

Optimized a U.S.–New Zealand business structure, resolved compliance concerns, and implemented proactive tax planning.

READ THE FULL CLIENT STORY

Frequently Asked Questions

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.

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.

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.

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

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.

Strengthen Your International Growth Strategy

Improve operational visibility and support more scalable international growth through a more coordinated cross-border approach.

Request a Free Consultation