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Expanding your business into the US

Understanding and navigating US Tax rules

For many UK businesses, the most confusing part of US expansion can be understanding the transatlantic tax implications and the US tax system.

Our US UK Private Client team specialise in helping people navigate the US and UK tax rules. Our US Expansion team aim to provide the same service to businesses.

The team provide practical advice to business owners and CFOs looking to expand into the US market and ensure all required US federal and state Corporate Tax filings are satisfied on a timely basis.

The following information has been collated through our experience of helping businesses with their US expansion and is intended to help transatlantic business managers understand the US tax rules that apply to businesses expanding into the US.

US Tax Team

Glossary of terms

US Trade or Business

Considerable, continuous and regular operation in the US

Permanent Establishment

Generally, a fixed place of business including a branch, office, factory workshop or place of management

Effectively Connected Income

Income that is connected with the operations of a US trade or business


A connection between a business and a state which triggers state taxation

US Corporation Tax issues for UK limited companies engaged in a US trade

Are you a non-US company doing business in the US? Do you know if you are subject to US Corporation Tax?

The tax requirements for non-US businesses engaged in a US trade can be complicated and require careful planning.

Michael & Alex US Insights 1

Expanding into the US

The US represents a huge untapped market for UK businesses. However, any business considering expanding into the US need to be aware of the complexities of the US tax system.

US Insights Alex And Michael

If you live in the UK and invest in the USA, then beware of the US Limited Liability Company (LLC)

US LLCs are a type of private limited company. They offer investors limited liability and also have an attractive tax profile under the US Internal Revenue Code.

This combination has resulted in LLCs being widely used in the USA as pooled investment vehicles. Such structures raise no issues for the investor who is resident in the USA. However, the picture can change dramatically in an international context.

US Insights - Alex Straight

US Insights

Access our full range of US Insights videos and accompanying articles where our US UK Private Client team explain some of the key tax considerations for US citizens living in the UK.

To help transatlantic business owners plan for the year ahead, we have prepared a calendar which details all the relevant US & UK corporate tax filing & payments dates in one place.

Podcast: BRave Business

Expanding from the UK to the US

In this episode we take a look at the key considerations for expanding your UK business to the US. What expansion options are available to you, which kind of businesses tend to succeed, and what are some of the common challenges UK businesses face?

Joining Declan for the conversation are Blick Rothenberg’s US UK Private Client Partner Michael Holland and our guest Brad Doline, Of Counsel at law firm Wilson Sonsini.

US Expansion – 12 Steps

US Corporate Tax

US Corporate tax can be complicated, and for businesses subject to both US & UK tax rules the situation can quickly become overwhelming.

Transatlantic businesses are subject to additional US tax reporting requirements, many of which are subject to significant ‘failure to file’ penalties.

While many domestic advisors are adept at domestic US corporation tax reporting, very few are able to provide joined up US & UK advice and compliance services.

Whether you are a start-up entrepreneur, a wealthy family with complex affairs, or a business executive, our dual-qualified team of tax advisers will look after your US UK personal tax affairs as well as those of your business.

If you wish us to contact you or want to discuss your situation, please complete the form below and one of our team will be in touch.

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Michael Holland
Michael Holland
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