Built for Growth — Structured for Global Ownership

Navigate IRS reporting, cross-border tax exposure, and ownership structuring with a coordinated strategy built for established businesses.

Running a U.S. business with foreign ownership creates a layer of complexity that standard tax approaches don’t address.From foreign-owned entity reporting to cross-border tax exposure and inefficient structures, issues often remain hidden until they begin impacting profitability, compliance, and scalability.We help you align your entity structure, tax strategy, and ongoing reporting so your business operates efficiently — and is built to scale.

When Structure, Tax, and Accounting Are Aligned,
Everything Works Better

Without the right strategy, quiet inefficiency and hidden exposure can compound as the business grows, leading to:

✔ Missed or incorrect foreign-owned entity filings (5472, 1120)
✔ Structures that create unnecessary tax at the owner level
✔ Inefficient movement of funds between the U.S. and foreign owners
✔ Disconnect between U.S. and international tax strategies

Strategic Support for U.S Based Business Foreign Owners

Lodder CPA specializes in cross-border complexity. We help you navigate both U.S. requirements and the international implications of how your business is set up and operates.

Entity Structure & Ownership Alignment
‍We evaluate whether your current structure actually supports your operations and long-term plans — and where it may be creating unnecessary tax or limitation.

Cross-Border Tax and Accounting Strategy
We align your U.S. tax position with the realities of foreign ownership, including profit allocation, withholding exposure, and treaty considerations.

Compliance & Reporting Accuracy
We ensure your business is meeting all IRS requirements specific to foreign-owned entities — without overpaying or overcomplicating.

Advisor Coordination & Alignment
We work alongside your existing accountants, legal counsel, and international advisors to ensure your structure, tax strategy, and decisions are fully aligned across jurisdictions.

Ongoing Advisory & Optimization
As your business grows, your structure needs to evolve with it. We provide ongoing guidance to keep everything aligned and efficient.

A Clear Path to a Stronger Structure

Structure & Filing Review
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‍We assess your current entity setup, ownership structure, and prior filings to identify gaps and risks.

Exposure & Opportunity Mapping
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‍We pinpoint where tax inefficiencies and compliance risks exist and where improvements can be made.
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Strategic Alignment
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‍We implement a structure, accounting, and tax approach that supports both compliance and long-term efficiency and work with other advisors on your team to ensure a unified strategy.

Ongoing Advisory
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‍We continue to refine your strategy as your business grows, ensuring your structure keeps pace with complexity.

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Trusted by International Founders Operating in the U.S.

"Working with Lodder CPA has been consistently excellent. Their deep expertise in U.S. international tax, especially for foreign founders, global entities, and cross-border operations, aligns perfectly with the needs we see… They understand the unique challenges of businesses entering or operating in the U.S., and they deliver clear, accurate guidance that helps our clients stay compliant and confident."

Travis Price

Mercury

"I’d very highly recommend Lodder CPA to anyone with a complex tax situation. As an expat with a foreign business, things get quite complicated… Their service is very personalized with video walkthroughs explaining what needs to be done. All of the employees. were professional and very communicative."

Edward Hanko

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.

If your business has foreign ownership, your tax structure and reporting obligations are more complex than they appear.

Lodder CPA helps you reduce risk, improve efficiency, and ensure your structure supports how your business actually operates today — and where it’s going.

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