Frank Hirth recognises that a business owner's personal and business affairs are often intertwined, and our privately owned business team focusses on US individuals with international business interests. We aim to provide companies, partnerships and sole traders with practical, incisive tax advice sympathetic to the individual tax situation of the business owners.
Each member of the team, whether based in our New York, London or Wellington office, is dual qualified in both UK and US tax so we have extensive experience of the interaction between the two tax regimes, including an in-depth understanding of the mechanisms of the UK-US tax treaty and other international tax agreements.
The US tax authorities place a significant compliance and reporting burden on US citizens and residents holding interests in non-US entities. Complex anti-avoidance legislation, including the Controlled Foreign Corporation (CFC) and Passive Foreign Investment Company (PFIC) rules, further complicate the tax position of US citizens with business interests overseas.
Our team is well placed to advise on these matters, proposing alternatives and advising on tax-efficient structures as required. We also work closely with other teams within the firm providing a seamless, integrated approach that can be tailored to the unique needs of your business and personal circumstances.
Services for Privately Owned Businesses include advice and guidance on:
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IRS offers filing and penalty relief to individuals subject to the new ‘transition tax’ - Individual US shareholders owning 10% or more of a controlled foreign corporation are subject to a special tax charged on undistributed…
+44 (0)20 7833 3500
London: 236 Gray's Inn Rd, London WC1X 8HB, UK
+1 212 465 7800
New York: 100 Wall St, Suite 802, New York, NY 10005, USA
+64 4 499 6444
Wellington: Level 4, Office 2, 24 Johnston Street, Wellington 6011, New Zealand