US International Tax Accountant – Foreign-Owned LLC Late Filings (5472 / ECTI)

We are looking for an experienced U.S. international tax accountant to help bring a foreign-owned U.S. LLC into full compliance after several years of unfiled returns.

The company has been operating for a number of years and has recently experienced significant growth. Due to restructuring and cross-border operations between the United States and the United Kingdom, historical filings were not completed and now need to be addressed correctly.

We are seeking a specialist who has direct experience with foreign-owned U.S. entities, particularly where multiple years of late filings need to be corrected.

The work will involve reviewing our internal accounts, advising on the correct historical treatment of the entity, preparing the required delinquent filings, and helping establish the most tax-efficient structure going forward.

You will also need to coordinate with our UK accountants to ensure the U.S. and UK tax positions are aligned.

This is not a bookkeeping role. We are specifically looking for a CPA or tax professional experienced in international and cross-border taxation.

Key Areas of Expertise Required

Applicants should have strong experience with:

• Foreign-owned U.S. LLC compliance

• Late filing remediation and penalty mitigation

• Form 5472 reporting requirements

• ECTI (Effectively Connected Taxable Income) determinations

• 1120-F filings for foreign-owned entities

• 1040-NR filings where applicable

• U.S.–UK cross-border tax considerations

• Entity classification elections (Disregarded Entity vs C-Corporation)

Experience dealing with multiple years of delinquent filings is essential.

Scope of Work

The project will likely include:

• Reviewing internal financial records for historical years

• Determining the correct tax classification of the LLC historically

• Preparing and filing any required late informational returns

• Determining whether Effectively Connected Taxable Income (ECTI) applies

• Filing any required federal tax returns depending on the classification

• Advising whether a C-Corp election or alternative structure would be beneficial going forward

• Advising on the correct treatment of transactions between the U.S. entity and foreign entities

• Coordinating with our UK accountants to ensure the structure works in both jurisdictions

Ideal Candidate

The ideal candidate will:

• Be a CPA, EA, or experienced U.S. international tax specialist

• Have direct experience with foreign-owned LLCs

• Be familiar with Form 5472 compliance and penalty mitigation

• Have experience with cross-border U.S.–UK tax issues

• Be comfortable reviewing historical records and recommending the best corrective approach

Long-Term Opportunity

While this project focuses on resolving historical compliance, we would ideally like to find an accountant who could continue working with us long-term if the relationship is a good fit.

To Apply

Please briefly describe:

Your experience with foreign-owned U.S. LLC compliance

Any experience handling late Form 5472 filings or similar situations

Your experience with cross-border U.S.–UK tax structures

Please begin your proposal with the words “International Tax” so we know you have read the full brief.

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