Skip to content
HorizonUK Tax Solutions

Cross-Border Business

What happens to my UK limited company if I move to the USA?

Answered by Jordan Onraet-Wells, Founder & Chartered Tax Adviser (CTA). Published 9 August 2026. Last reviewed 9 August 2026.

The short answer

You can keep it, and on the UK side little changes: a UK-incorporated company stays UK tax resident and inside UK corporation tax at 19% to 25% wherever its director lives. The complication is American. From the day you become a US tax resident, a company you majority-own becomes a controlled foreign corporation, bringing annual Form 5471 reporting and potential GILTI tax on profits you have not even drawn. The keep, close or restructure decision is far cheaper to make before your US residency starts, because the best closure reliefs only work while you are still UK resident.

  • A UK-incorporated company is automatically UK tax resident under the incorporation rule and keeps paying UK corporation tax at 19% to 25%; the US, unusually, fixes federal corporate residence by place of incorporation too, so the dual-residence fight is rare.
  • Once a US-resident person owns more than 50%, the company is a controlled foreign corporation from day one: Form 5471 is due annually and GILTI can tax undistributed profits on your personal US return, though UK corporation tax already paid usually softens the cash cost through foreign tax credits.
  • The UK charges no withholding tax on dividends, so once you are a US resident the tax on dividends lands in America, often at qualified-dividend rates.
  • Closing before departure can secure capital treatment: distributions of £25,000 or less via strike-off, any size via an MVL, with Business Asset Disposal Relief at 18% from 6 April 2026, subject to the TAAR and the five-year temporary non-residence rule.
  • Dormancy is overrated: it switches off UK corporation tax but not Companies House filings or CFC reporting in the US system.

The UK side carries on almost unchanged

There is no UK rule against a company having a US-resident sole director and shareholder. The company keeps trading, keeps filing and keeps paying corporation tax at 19% on profits up to £50,000 and 25% above £250,000, with marginal relief between. Unlike most destinations, the USA does not usually claim the company either: US federal law fixes corporate residence by place of incorporation alone, so running the board from Texas does not make it US resident. The realistic company-level exposures are a US permanent establishment if you habitually conclude contracts from an American desk, and state-level doing-business rules, so document where control sits from day one, as for any director running a UK company from abroad. Dividends stay quiet on the UK side, since the UK levies no withholding tax, and are taxed on your US return instead.

The US side: CFC status, Form 5471 and GILTI

A controlled foreign corporation is a foreign company more than 50% owned, by vote or value, by US shareholders each holding at least 10%. A sole shareholder who becomes a US tax resident takes their UK Ltd over that line on day one, with no grace period. Form 5471 is then due every year, with significant penalties for missing it, and the GILTI regime can pull a slice of the company's undistributed profits onto your personal US return as they arise. Because UK corporation tax runs at 19% to 25%, foreign tax credits often reduce the extra US cash cost substantially, but the computations and forms are still required, and your state may tax the income without the federal reliefs. A check-the-box election on Form 8832 can remove the CFC machinery at the price of making you personally taxable on profits as they arise, similar in kind to the issues we cover for US LLCs owned by UK residents. The US analysis and filings are handled by our US partners (Enrolled Agents and CPAs), whom we coordinate for you.

Decide before your US residency starts

If the business will not genuinely continue, closing before departure is usually the honest answer: while still UK resident you can take reserves as capital, under the £25,000 strike-off rule or through a members voluntary liquidation, with Business Asset Disposal Relief at 18% from 6 April 2026 if you qualify, and money extracted before US residency starts normally stays out of the US return entirely. Watch the two-year anti-phoenixing rule if you will do similar work in America, and the five-year temporary non-residence rule if you may return to the UK; our guide to closing a UK company when leaving the UK works through the mechanics. Dormancy rarely helps, since Companies House filings and US CFC reporting continue for a shell earning nothing. Every favourable option narrows once the US clock starts, so Horizon models keep versus close on your actual numbers, on fixed fees agreed upfront; book a free clarity call at /book before you fix a moving date.

Go deeper

Sources and further reading

This is general information for the 2026/27 UK tax year, not personal tax advice; speak to a Chartered Tax Adviser about your own position.

Applies to you? Ask us directly

A page can only take you so far. Book a free 30-minute clarity call with Jordan, a Chartered Tax Adviser, and get this answered for your exact situation, on a fixed fee agreed upfront.

All quick answers
WhatsApp