Cross the Atlantic with a finance team that
already lives on both sides.
Most accountants pick a side. We don't. CloudFin Labs runs finance simultaneously in the US and UK: entity setup, tax structuring, payroll, treasury, and the GTM finance to back your launch.
UK companies, landing in America
You've raised in London or Cambridge. Now your buyers, your investors, or your next round are in the US. We make the move look effortless.
- 01
Delaware C-Corp setup
Incorporation, EIN, registered agent and banking, usually within 10 business days.
- 02
Flip / topco structuring
When investors require a US parent. We coordinate with counsel on both sides.
- 03
PEO & state payroll
Hire your first US employees compliantly across any state without your own infra.
- 04
US GAAP conversion
From FRS 102 to GAAP for board, audit, and US investor reporting.
- 05
Sales tax (Avalara/TaxJar)
Nexus assessment, registration, automated filing across 50 states.
- 06
US fundraise readiness
409A, cap table cleanup, US-style metrics, model and data room.
US companies, opening in Britain
London is your bridge to Europe. We handle the entity, the payroll, the VAT and the R&D credits, so your team can focus on the launch.
- 01
UK Ltd incorporation
Companies House setup, PSC register, VAT and PAYE, done in days not months.
- 02
Branch vs subsidiary
We model the tax and operational trade-offs before you commit.
- 03
Transfer pricing
Defensible inter-company agreements, mark-ups, and documentation.
- 04
R&D tax credits
HMRC claims for qualifying engineering, often 18–27% back on UK spend.
- 05
UK payroll & EOR
Hire UK talent through PEO/EOR or your own entity, fully compliant.
- 06
VAT & MTD compliance
Registration, returns and Making Tax Digital, set up clean from day one.
A 90-day expansion playbook.
Tax, structure, hiring, banking. We map every constraint and pick the right entity strategy.
Incorporate, open accounts, set up payroll, configure systems, draft inter-company agreements.
First payroll runs, first close, first board pack from the new geography. You launch live.
The acronyms that wreck good companies.
Once a US person owns more than 50% of a foreign company, that company becomes a Controlled Foreign Corporation (CFC) and a stack of US tax rules switches on. Get the structure right at incorporation and the exposure stays manageable. Get it wrong and you pay tax on profits you never distributed.
We build the structure, the inter-company agreements, the elections (check-the-box, GILTI high-tax, §962) and the filings (Forms 5471, 8858, 8865, 8992, 8993) so your founders, your board and your auditor all see the same number.
Controlled Foreign Corporation
Triggered when US shareholders (10%+ each) collectively own >50% of a foreign entity. Switches on Subpart F, GILTI, and Form 5471 reporting from day one.
Global Intangible Low-Taxed Income
Annual US tax on a CFC's earnings above a 10% return on tangible assets. Effective ~10.5–13.125% for C-corps; up to 37% for individuals unless a §962 or high-tax election is made.
Passive & related-party income
Royalties, interest, dividends and certain inter-company sales flow up to the US shareholder immediately, taxed at full US rates regardless of distribution.
Inter-company at arm's length
Cost-plus, services and IP licence agreements between US/UK entities, supported by benchmarking and contemporaneous documentation. Defends margins under HMRC and IRS audit.
Passive Foreign Investment Co.
Cash-rich UK Ltd holding investments can drift into PFIC territory for US individual shareholders. Painful tax + Form 8621. Avoidable with structure and timing.
15% global minimum tax
OECD BEPS rules now in force in the UK and EU. Groups above €750M revenue face top-up tax. We track the in-scope threshold and the GloBE filings on the way there.
UK founder, US C-Corp on top
Classic flip. The UK Ltd becomes a CFC of the US topco. GILTI hits the C-Corp at ~10.5%. Manage with high-tax election and clean transfer pricing.
US founder, UK Ltd subsidiary
Day-one CFC. Form 5471 every year. Individual shareholders should consider a §962 election or interpose a US C-Corp to access the GILTI deduction.
Dual-resident exec team
Equity, payroll and social security split across HMRC and the IRS. Treaty positions, totalisation, and 83(b) timing all matter, before grants are signed.
* General guidance, not tax advice. We work alongside qualified US and UK tax counsel on every engagement.