Form 5471: your UK limited company, reported to the IRS.
A US person who owns or controls a foreign corporation files Form 5471 each year with their personal return. It is one of the most demanding forms in the code, and one of the most heavily penalised for silence.
Figures on this page are stated for tax year 2025/26 UK · 2025 US. Thresholds change annually.
Which category of filer you are
The form has several filer categories, driven by how much of the company you own and what happened during the year. A sole American director-shareholder of a UK company is typically a Category 4 and 5 filer, reporting the company's full accounts, its earnings and profits, and its balance sheet — restated under US principles.
Even acquiring or disposing of a shareholding crosses a reporting threshold, so the form frequently appears in years when nothing else changed.
- $10,000 penalty per form, per year, for late or missing filings
- Schedules J, P and Q track earnings, profits and taxes
- The return stays open for assessment until the form is filed
GILTI, and the elections that soften it
Controlled foreign corporation rules can tax you personally on the company's retained profits before any dividend is paid — Subpart F for certain passive income, GILTI for most active profit. For an owner-managed UK company that can mean a US bill on money still sitting in the business account.
A Section 962 election, or in some cases a check-the-box election treating the company as transparent, changes the arithmetic substantially. Which one wins is a numbers exercise we run before recommending anything.
Questions we get about this
If you are a US person with more than 50% ownership or control, generally yes - size is not the test.
The form applies to a one-person consultancy the same way it applies to a substantial group, which surprises most owner-managers.
A rule that taxes the US owner personally on the company's active profits each year, whether or not anything is distributed.
Elections exist that reduce or defer the effect, but they must be made deliberately - the default outcome is usually the worst one.
$10,000 per form per year to start, with further penalties if it continues after notice, and the tax year stays open indefinitely until it is filed.
Missed years are commonly resolved through the Streamlined procedures, which waive the penalty where the failure was non-wilful.
They will prepare the statutory accounts, which is the starting point - but the form requires those figures restated under US rules and reconciled to earnings and profits.
We work from your existing accounts rather than duplicating the bookkeeping.
Related pages
- Service
Foreign tax credit (Form 1116)
Form 1116 foreign tax credit explained: income baskets, the limitation formula, carryback and carryforward, and when credits beat the exclusion.
- Service
Business & corporate tax
Cross-border business structuring: UK limited companies under US rules, GILTI, permanent establishment and expansion in either direction.
- Pillar guide
Tax specialists for US and UK
What US and UK tax specialists handle that a general accountant does not: residence tests, treaty relief, FBAR, PFICs, pensions, property and catch-up filings.
- Free tool
FBAR threshold checker
Check whether your non-US accounts crossed the $10,000 aggregate FBAR trigger at any point in the year, and what to do if they did.
- Who we help
Planning a move
Moving between the US and UK: pre-move planning, split-year treatment, and the decisions that are far cheaper made before departure than unwound afterwards.
- Glossary
FBAR: definition
The Foreign Bank Account Report — FinCEN Form 114 — and its $10,000 aggregate trigger.
Further reading
- Form 8621: who files it, when, and for how many funds
One form per fund, attached to your return, with a small-holdings exception most people have never heard of. Here is how the filing side actually works.
- Form 8938 vs the FBAR: two reports, one set of accounts
Same accounts, two different reports, two different agencies. Here is what separates the FATCA form from the FBAR, and why many expats file both.
Official sources
Last reviewed · Figures stated for tax year 2025/26 UK · 2025 US. Thresholds and rates change annually — check figures against the current tax year before relying on them.
Not sure how this applies to you?
Describe your situation and we will tell you which forms are actually required, with a fixed fee to prepare them.