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U.S. Owners of Foreign Companies

You own a company abroad. The IRS still wants the full story.

If a U.S. person or company owns a foreign corporation, you're likely a Form 5471 filer with GILTI and Subpart F exposure — whether you've heard those words or not. Your U.S. shareholder may be a C-corp, an S-corp, a partnership, or an individual; we make the foreign ownership fully compliant and tax-efficient for whichever it is, on one fixed annual fee.

CPA-led, U.S. licensed since 2013 Fortune 500 international-tax background Houston-based, serving the U.S. & abroad

Se habla Español  ·  Se fala Português. Fixed-fee engagements — you always know the price before work begins.

The stakes

Foreign ownership is where good taxpayers get blindsided

These aren't obscure forms — they're high-penalty, high-complexity filings most U.S. preparers simply don't handle.

01

$10,000+ for a late Form 5471

Each late or incomplete Form 5471 starts at a $10,000 penalty, with more stacked on for continued failure — and it can keep the shareholder's entire return open for audit indefinitely.

02

NCTI/GILTI can tax profits you never brought home

A U.S. shareholder of a controlled foreign corporation can owe U.S. tax — through the rules now called NCTI (formerly GILTI) and Subpart F — on the company's earnings even if not a dollar was distributed. Planning — the §250 deduction for corporates, a §962 election for individuals, the high-tax election — can dramatically change the bill.

03

FBAR & FATCA run in parallel

Foreign accounts and assets carry their own reporting, with their own penalties. Owning the company is only half the compliance picture.

Is this you?

For U.S. owners of a foreign business — corporate or individual

Companies and individuals that built or bought something overseas — and want it handled correctly on the U.S. side. The shareholder might be your U.S. C-corp, S-corp, or partnership, or you personally.

Tell us about your situation
  • A U.S. C-corp, S-corp, partnership, or individual owning 10%+ of a foreign company
  • Earning profits abroad that may trigger GILTI or Subpart F inclusions
  • Holding one or more controlled foreign corporations (CFCs)
  • Weighing the §250 deduction, a §962 election, or foreign tax credits
  • Also handling FBAR, Form 8938, and foreign income on the U.S. return
  • Behind on filings and worried about catching up the right way
Transparent, fixed-fee pricing

Fixed annual pricing — calmer than a monthly retainer

Outbound ownership tends to be project-style, once-a-year work. Pick the tier that matches your structure; most owners with GILTI in the picture choose Growth.

Outbound Compliance

One U.S. shareholder (entity or individual), one CFC, no NCTI/GILTI complexity, under $2M foreign revenue.
$4,500/yr
$1,000 one-time setup · 50% deposit
  • Your U.S. shareholder return as applicable — 1120, 1120-S, 1065, or 1040
  • Form 5471 for your first CFC (Category 4 or 5, no NCTI)
  • Foreign tax credit (Form 1116 or 1118)
  • FBAR + Form 8938 where applicable
  • One state return
  • Annual planning call
Start with this plan
Most Popular

Outbound Growth

NCTI/GILTI applies, $2M–$10M foreign revenue. Built around your first CFC; a second is easy to add.
$9,500/yr
or $850/mo · $1,500 setup
  • Everything in Compliance, plus:
  • NCTI/GILTI calculation + Form 8992
  • §250 deduction analysis (corporate shareholder)
  • §962 election review (individual shareholder)
  • Transfer-pricing memo — 1 transaction type
  • Includes your first CFC; each additional CFC +$1,800
  • Mid-year planning call
Start with this plan

Outbound Strategic

Subpart F + NCTI, multiple CFCs, complex repatriation strategy. Built around your first two CFCs.
$27,000/yr
or $2,300/mo · $2,500 setup
  • Everything in Growth, plus:
  • Subpart F analysis + Schedule I
  • Form 8993 (FDDEI/FDII, corporate shareholder)
  • Includes your first two CFCs; each additional +$1,800
  • Transfer-pricing method & agreements — up to 3 transaction types
  • High-tax exclusion (HTE) analysis
  • Quarterly planning calls
  • Annual repatriation / distribution memo
Start with this plan
Already behind on filings? Catching up the wrong way can make things worse. We run Streamlined Filing Compliance engagements (3 years of returns + 6 years of FBAR + the required certification) for $4,500–$7,500. Ask about quiet, correct catch-up on your call.

Fees are starting points and depend on the number of CFCs, income types, and elections involved. A 50% deposit secures your engagement; the balance is due at delivery. PFIC filings and §367 outbound transfers are quoted separately.

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.

Book a session — $750
Why Delancy CPA?

International tax is the specialty, not a sideline

Most CPAs see a 5471 a handful of times a year, if ever. For us, controlled-foreign-corporation work is core.

2013CPA licensed in the U.S. since 2013
Fortune 500In-house international-tax department experience
CFC5471, NCTI/GILTI, Subpart F & §962 are routine here
GlobalServing U.S. owners with operations worldwide
Our easy process

From first call to filed & handled

No surprises, no scope creep, no jargon. Just a clear path and a fixed fee.

1

Free strategy session

We confirm your filing categories and spot GILTI/Subpart F exposure early.

2

Engagement letter

A fixed annual fee and clear scope, in writing, before work begins.

3

Secure onboarding

Share your foreign financials and prior returns through our portal.

4

File & plan

We prepare, file, and give you a forward plan to lower next year's bill.

Questions, answered

Owning a foreign company, answered

I already have an accountant for the U.S. return. Why do I need you?

Most preparers — whether they do your 1120, 1120-S, 1065, or 1040 — don't handle Form 5471, GILTI, or Subpart F, and won't know if they got it wrong until the IRS does. We work alongside or in place of your current preparer specifically for the international layer.

What is GILTI and will it affect me?

GILTI (now often referenced as NCTI) can tax a U.S. shareholder on a controlled foreign corporation's earnings even with no distribution. Whether and how much you owe depends on the company's income, foreign taxes paid, and elections like §962 or the high-tax exclusion — all of which we analyze for you.

Should I make a §962 election?

Sometimes it sharply reduces the tax on GILTI for individual owners; sometimes it doesn't help. It's fact-specific, which is why our Growth and Strategic tiers include a review of whether it's right for you.

I haven't filed these forms for past years. Am I in trouble?

Often there's a clean path forward through the IRS streamlined or other voluntary procedures, especially if the failure was non-willful. The worst move is a noisy or incorrect catch-up. We'll advise the right approach privately on your consultation.

Do you handle the FBAR and Form 8938 too?

Yes — foreign account and asset reporting is included in every outbound tier. Owning the company and reporting the accounts are two separate obligations, and we cover both.

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).

Make your foreign company fully compliant — and tax-efficient

Book a free strategy session. We'll confirm exactly which forms you owe, flag GILTI exposure, and quote a fixed annual fee.

Prefer to talk now? Call 832-304-4545  ·  info@DelancyCPA.com