U.S. Businesses Operating Internationally Need More Than Compliance

Cross-border operations introduce tax complexity, structural decisions, and coordination challenges that directly impact profitability and long-term growth.

We help bring clarity, alignment, and strategy to how your business operates across jurisdictions.

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

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:

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

01
Revenue generated across multiple countries
without a clear, unified tax strategy
02
Foreign entities or subsidiaries established over time without a coordinated structure
03
Advisors in different jurisdictions working independently, without full alignment
04
Growing uncertainty around tax exposure, reporting requirements, and how profits should be handled
HOW WE HELP

How We Support Your International Operations

01
Structured Entity Design

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

02
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.

03
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.

04
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.

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

“They are my US company accountants, Lodder CPA, and they specialize in US/International business relationships and tax structures. I have found them to be ethical, honest and accurate in their services.”

Mike Stevens
Middle Digital Ltd.

INTERNATIONAL STRUCTURES

Built for Complex International Structures

Our work goes beyond basic compliance. We support businesses operating across jurisdictions where structure and planning directly impact tax outcomes.

  • Form 5471 (foreign corporations)
  • Form 8865 (foreign partnerships)
  • Form 8858 (disregarded entities)
  • Foreign tax credit planning
  • GILTI/NCTI, PFIC and Subpart F exposure
TAX INVESTMENT

The Right Level of Support for Your Situation

Our advisory support is designed to align with the complexity of your structure and the level of strategy, coordination, and oversight your situation requires as it grows.

Full-Service Tax Package

Structured tax package designed to keep your filings accurate, compliant, and optimized.
What's Included:
Preparation of Business Corporate Federal Income Tax Return
Tax return walk-through (by recorded Loom video)
Tax Strategy Meeting (during the fourth quarter of the operating year) to optimize your tax position on your goals and circumstances
Tax Optimization checklist
Tax Projection
Safe Harbor estimated quarterly taxes
Estimated tax payment reminders (general alert)
Government notice review
Email and Phone support

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.

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.

Bring Clarity and Control to Your International Operations

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