International Tax Planning
Selling across borders shouldn't cost you twice.
Cross-border tax is where eCommerce founders quietly lose the most money — to double taxation, missed treaty positions, surprise VAT, and structures that made sense at $1M but break at $10M.
We build the structure, file the forms, and defend the positions — for US founders going global and foreign founders entering the US.
Who this is for
International tax problems don't look international at first.
They look like a VAT registration notice from HMRC, a 1099 with the wrong withholding, or a CPA quietly telling you they don't do 5471s. If any of this sounds familiar, we should talk.
US founders selling abroad
You're shipping into the UK, EU, Canada, or Australia and getting blindsided by VAT registrations, foreign tax filings, or surprise withholding on payouts.
Foreign founders selling into the US
You're based outside the US but Amazon FBA, Shopify, or your warehouse-of-record creates a US tax footprint you didn't sign up for.
Multi-entity eCommerce groups
You already have US and foreign entities and need transfer pricing, intercompany agreements, and a defensible structure your auditors won't unwind.
Founders relocating or expatriating
You're moving to Portugal, Dubai, or Puerto Rico — and want to keep your eCommerce business running without breaking US residency or CFC rules.
What we cover
One firm for the whole cross-border picture.
Entity structuring across borders
We map your sales channels, fulfillment, IP, and ownership to the right combination of US LLCs, C-corps, and foreign entities — so each layer earns its keep and nothing is taxed twice.
GILTI, Subpart F & CFC planning
If you own a foreign company, the IRS taxes most of its income whether you take it out or not. We model GILTI inclusions, high-tax elections, and 962 elections to keep your effective rate sane.
Foreign tax credits & treaty positions
Properly claimed FTCs and treaty-based return positions can erase double taxation. We document the positions, file the forms (8833, 1116, 1118), and defend them if challenged.
Transfer pricing for eCommerce
Intercompany inventory, IP licensing, management fees, and cost-sharing — priced and documented in line with §482 and OECD guidelines so your margins land in the right jurisdictions.
VAT, GST & foreign sales tax
UK VAT, EU OSS/IOSS, Canadian GST/HST, Australian GST — we determine where you have to register, get you registered, and integrate filings with your accounting stack.
Inbound US tax for foreign sellers
ECI vs FDAP, US trade-or-business analysis, withholding (W-8BEN/W-8BEN-E), branch profits tax, and 1120-F filings for non-US owners selling into the US.
Founder residency & expatriation
Pre-move planning for founders relocating abroad, expatriation under §877A, Puerto Rico Act 60, and tracking the day-counts and tie-breakers that actually decide your residency.
Cross-border M&A and exits
Structuring a sale when buyers, sellers, or IP sit in different countries — Section 338(g) elections, F-reorgs, and pre-sale restructuring to maximize after-tax proceeds.
How we work
From scattered exposure to a structure you can defend.
01
Diagnostic
We map your current footprint — entities, sales channels, fulfillment locations, ownership, and where cash actually lands — and flag the exposures hiding in it.
02
Plan
You get a written cross-border plan: recommended structure, elections to make, filings you owe, and a year-by-year tax projection so there are no surprises in April.
03
Execute & maintain
We implement the structure, file the forms (5471, 5472, 8858, 8865, 1120-F, 1116, 8833, FBAR, 8938), and update the plan as you expand into new countries.
Why ECOM CPA for international work
We've been doing US-tax work for eCommerce founders for over a decade. The international layer isn't a side practice — it's built around how our clients actually grow: new marketplaces, new warehouses, new countries, new owners. You get a team that has filed every form on the list above, many times, for businesses that look like yours.
Ready to map your cross-border picture?
Book a free consultation and we'll walk through your structure together.