Form 5471 & GILTI Tax for Expats Owning Foreign Corporations | NationRules
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Foreign Corporations & Form 5471

A deep-dive tax guide on U.S. reporting requirements (GILTI, CFCs, and Form 5471) for expats owning Canadian CCPCs, UK Ltds, or German GmbHs.

Controlled Foreign Corporations (CFC)

When you move to the U.S. and establish U.S. tax residency (under green card status, H-1B, L-1, or the Substantial Presence Test), your overseas business is classified by the IRS as a **Controlled Foreign Corporation (CFC)** if U.S. shareholders own more than 50% of the total vote or value.

This has profound consequences for business owners from:

  • Canada (CCPCs): Your Canadian-Controlled Private Corporation will likely lose its CCPC status under CRA rules because it is controlled by a Canadian non-resident. This triggers departure tax and eliminates the Canadian Small Business Deduction.
  • United Kingdom (Ltd Companies): A UK private limited company controlled by a U.S. tax resident is treated as a CFC, requiring complex balance sheet disclosures.
  • Germany (GmbHs): Subject to strict double-taxation credit rules and CFC look-through guidelines.

GILTI High-Tax Exception Calculator

Under the Tax Cuts and Jobs Act (TCJA), earnings of a CFC are subject to the **GILTI (Global Intangible Low-Taxed Income)** regime, which taxes undistributed profits as personal income. However, you can exclude income if the local corporate tax rate is at least **18.9%** (90% of the U.S. corporate tax rate of 21%).

Examples: UK corporate baseline is 25% (eligible). Canadian CCPC using the Small Business Deduction is ~12.2% (subject to GILTI).

Form 5471 Filer Categories

You must file Form 5471 if you fall into any of the following IRS filer categories:

CategoryApplies ToFiling Requirement
Category 2U.S. officers or directors of a foreign corporation in which a U.S. person acquires 10% or more ownership.Acquisition filing.
Category 3A U.S. person who acquires a cumulative 10% or more ownership, or disposes of ownership to drop below 10%.Acquisition/Disposition filing.
Category 4A U.S. person who controls a foreign corporation (owns >50% vote or value) for 30+ consecutive days.Full balance sheet & transaction disclosure.
Category 5A U.S. shareholder who owns 10% or more of a Controlled Foreign Corporation (CFC).Subpart F & GILTI details.