Owning a UK limited company is straightforward enough on the UK side: you incorporate at Companies House, pay Corporation Tax on profits, and extract money as salary and dividends. But if you're a US citizen or green card holder, that same company sits inside a second, far less familiar system — the US one — and the two don't always agree. This overview maps the entire US picture so you can see how the pieces fit, then points you to the deep-dive guides for each.
The short answer
A UK limited company owned by a US citizen is treated by the IRS as a foreign corporation — usually a controlled foreign corporation (CFC) — which adds a layer of US reporting and potential tax on top of all your normal UK obligations. The main US pieces are: annual Form 5471 reporting, possible GILTI/NCTI tax on profits you retain in the company, FBAR and FATCA reporting for company accounts, and careful planning around profit extraction and elections (check-the-box, Section 962). The company doesn't pay US tax itself — but as its owner, you can.
Key takeaways
- The IRS treats your UK Ltd as a foreign corporation, usually a CFC.
- Form 5471 is generally required every year, with a $10,000 penalty for non-filing.
- GILTI/NCTI can tax you in the US on profits you leave inside the company.
- Company bank accounts usually trigger FBAR and possibly FATCA reporting.
- Elections (check-the-box, Section 962) can change the result — but need modelling.
Executive summary
For a US owner, a UK limited company creates obligations on two axes at once. On the UK axis, nothing changes from any other company: Corporation Tax, statutory accounts, Companies House, payroll if you draw a salary. On the US axis, the company becomes a foreign corporation — and because you control it, a CFC — which means an annual information return (Form 5471), exposure to current US tax on retained profits (GILTI, renamed NCTI for tax years beginning after 31 December 2025), and information reporting for the company's accounts (FBAR, FATCA). The practical art of running an American-owned UK company is keeping both axes compliant while using the available elections to avoid being taxed twice on the same profits.
The UK obligations (unchanged)
Your UK duties are exactly what they'd be for any director-owner. We cover each in detail:
- Company accounts — statutory accounts and Companies House filing.
- Corporation tax — the tax your company pays on its profits.
- Payroll — if you pay yourself (or others) a salary.
- Bookkeeping — the records everything else depends on.
The point of this overview isn't to re-explain those — it's to show what the US adds.
The US obligations (the layer most people miss)
1. Form 5471 — the information return. As a US owner meeting one of the filer categories, you generally file Form 5471 every year reporting the company's income, balance sheet, and your ownership. It carries a $10,000-per-year penalty for non-filing, regardless of whether any US tax is due. This is the single most important US filing for an American-owned UK company — and the most commonly missed. See our dedicated guide: Form 5471 explained for Americans in the UK.
2. GILTI / NCTI — tax on retained profits. This is the one that surprises people most. Under the GILTI regime (renamed NCTI for tax years beginning after 31 December 2025), a US shareholder of a CFC can be taxed currently in the US on the company's profits — even if those profits stay inside the company and are never paid out. It's designed to stop US persons deferring tax by leaving money in a foreign company. We explain the mechanism, and the elections that soften it, in GILTI/NCTI rules for Americans with UK companies.
3. FBAR and FATCA — account reporting. Your UK company's bank accounts, where you have signature authority, typically count toward your FBAR reporting, and may also appear in your FATCA / Form 8938 reporting. These are separate filings from Form 5471 and your tax return.
4. Profit extraction — salary vs dividends, both ways. How you take money out has UK consequences (the usual salary/dividend efficiency question) and US ones (how the extraction interacts with foreign tax credits, GILTI/NCTI, and the treaty). The UK-efficient mix isn't automatically the US-efficient one.
How the pieces fit together
The mistake is treating these as separate problems. They're one system:
- Your structure (Ltd vs sole trader, and any check-the-box election) determines which US forms apply.
- Form 5471 reports the company; GILTI/NCTI taxes its profits; FBAR/FATCA report its accounts.
- Elections — check-the-box (Form 8832) and Section 962 — change how heavily the GILTI/NCTI layer falls.
- The US-UK treaty and foreign tax credits work to stop the same profit being fully taxed twice.
Get one piece wrong and it ripples through the others — which is why American-owned UK companies are genuinely a specialist area, not a bolt-on to standard UK accounting.
Common mistakes we see
- Running the UK company perfectly while ignoring the US entirely — until a Form 5471 penalty notice arrives.
- Leaving profit in the company to "save tax", not realising GILTI/NCTI may tax it in the US anyway.
- Forgetting the company accounts on the FBAR.
- Using a UK-efficient salary/dividend mix that's inefficient once US foreign tax credits are factored in.
- Never considering elections that could materially reduce the US burden.
Related reading
- Sole trader or limited company for an American in the UK? — the structure decision, if you haven't committed yet.
- Do US citizens need to report a UK limited company? — the compliance and reporting angle in detail.
- How UK corporation tax and US tax interact — the double-taxation mechanics.
This article is general information, not personalised advice. Running an American-owned UK company well means coordinating two tax systems and choosing elections that carry multi-year consequences. Book a free consultation and we'll map your specific company's US and UK obligations and the most efficient compliant path through both.