You hired in Dublin, Tallinn, or London. Now your U.S. tax got complicated.
A foreign subsidiary for engineering or sales is great for the company — and it instantly creates CFC filings, NCTI/GILTI exposure, IP transfer-pricing questions, and §174 R&E headaches. We give global startups one specialist team for all of it, priced for your stage.
Se habla Español · Se fala Português. Fixed-fee engagements — you always know the price before work begins.
Cross-border structure quietly creates U.S. tax obligations
The same moves that make a startup global — a foreign dev sub, IP arrangements, multi-state hiring — each trigger their own U.S. rules.
A foreign sub = Form 5471 from day one
Stand up a subsidiary in Ireland, Estonia, or the U.K. and you're a Form 5471 filer immediately — $10,000-per-form penalties included, even pre-revenue. A missing or incomplete 5471 can also hold your shareholder's entire return open to audit indefinitely under §6501(c)(8).
IP and intercompany pricing get scrutinized
Cost-plus service charges from a foreign dev shop, or any IP arrangement, need transfer-pricing support. Get it wrong and a future raise or acquisition turns it into a diligence problem.
§174 R&E capitalization hits cash
U.S. rules on capitalizing research and experimental costs — including software development — can create taxable income even when you're burning cash. It needs to be modeled, not discovered at filing.
For venture-stage and bootstrapped startups going global
Sophisticated founders who are cash-conscious now but want a structure that survives a Series B diligence later.
Tell us about your situation- A U.S. parent C-corp with one or more foreign subsidiaries
- Hiring engineers or salespeople abroad through a foreign entity
- Facing NCTI/GILTI, FDDEI/FDII, or Subpart F questions as revenue grows
- Moving or licensing IP between the U.S. and a foreign sub
- Capitalizing software / R&E costs under §174
- Wanting clean, investor-grade books and a defensible structure
Priced for your stage, built for your next round
Fixed monthly fees that scale with your sub count and complexity. Most funded startups with NCTI/GILTI in play choose Growth.
Global SaaS Starter
- Form 1120 for the U.S. parent
- Form 5471 for your first CFC (no NCTI computation if no income)
- Transfer-pricing memo — cost-plus services, 1 type
- State franchise/annual filing — one state included (Texas franchise report, or your state's equivalent)
- Full in-house bookkeeping (up to 50 transactions/mo)
- Quarterly call
Global SaaS Growth
- Everything in Starter, plus:
- Includes your first two CFCs; each additional +$1,800
- NCTI/GILTI · §250 · FDDEI analysis annually
- Transfer-pricing method & agreements — up to 3 types (services + cost recharge + intercompany loan)
- Multi-state (up to 5)
- Monthly in-house bookkeeping (up to 200/mo)
- Fractional CFO layer (6 hrs/mo)
Global SaaS Strategic
- Everything in Growth, plus:
- Includes your first five CFCs; each additional +$1,800
- CFO Standard (12 hrs/mo), investor-grade reporting
- Section 174 R&E capitalization analysis
- §163(j) interest-limitation modeling
- Quarterly tax planning
- Lead role on benchmarking when referred out
Fees are starting points based on entity count, ARR, and complexity. IP migration / cost-sharing arrangements, R&D credit studies, 409A valuations, and SAFE/convertible-note optimization are referred to specialists.
Not ready for a full engagement?
Start with a 60-minute Orientation Session — your realistic paths, your exact filing list and deadlines, and a one-page written summary. $750 flat, credited in full toward any engagement within 60 days.
A tax partner who understands both startups and structure
You need someone who can pass diligence and won't over-engineer your bill before you've raised.
From first call to filed & handled
No surprises, no scope creep, no jargon. Just a clear path and a fixed fee.
Free strategy session
We review your structure and flag CFC, GILTI, and IP issues early.
Engagement letter
A stage-appropriate fixed fee and clear scope, in writing, up front.
Onboard securely
Connect your books and share entity docs through our portal.
Scale with you
Compliance, planning, and CFO support that grows toward your next round.
Global startup tax, answered
We just set up a sub in Ireland to hire engineers. What did we trigger?
Almost certainly a Form 5471 filing for the U.S. parent, plus transfer-pricing support for the cost-plus charges between your U.S. company and the sub. If the sub becomes profitable, NCTI/GILTI and FDDEI analysis follows. We handle all of it in one package.
We're pre-revenue. Do we really need this now?
The compliance forms apply regardless of revenue — and the cheapest time to get your structure and intercompany documentation right is before a priced round puts it under diligence. Our Starter tier is built for exactly this stage.
What's the §174 issue everyone keeps mentioning?
U.S. rules require capitalizing and amortizing research and experimental costs, including much software development, rather than deducting them immediately. That can create taxable income even while you're burning cash. We model the impact so it's planned, not a filing-day surprise.
Can you support our IP licensing between entities?
We prepare the intercompany agreement and the surrounding documentation for services, cost recharges, and intercompany loans. For an IP license specifically, the contested number is the royalty *rate* — and real §6662(e) protection on a rate requires a royalty-rate benchmarking study, so we coordinate that study with a transfer-pricing economist rather than fold it into light documentation. IP buy-ins, platform contributions, and cost-sharing are specialist work we also refer out and quarterback for you.
Will your work hold up in fundraising or M&A diligence?
That's the point of doing it properly now. Clean books, filed international forms, and defensible intercompany documentation are exactly what acquirers and investors check. We keep you ready.
Do you only work with companies in Texas?
No. Federal international filings — Forms 5472, 5471, 1120-F, FIRPTA withholding — have no state boundary, and we serve foreign-owned companies in all 50 states. We're based in Houston, one of America's largest international business hubs, and we prepare state filings for whichever state your entity is in (Texas franchise reports included for Texas entities).
Build a global structure that survives diligence
Book a free strategy session. We'll map your entities, flag NCTI/GILTI and §174 exposure, and quote a fixed fee sized to your stage.