CFC & PFIC Advisory

Concerned About How US Investor Tax Rules Affect Your Business?

Why CFC and PFIC Rules Deserve Early Attention

Who We Are

Frazier & Deeter helps businesses assess and manage CFC and PFIC exposure with clear, practical guidance, so there are no surprises down the line.

US tax regimes such as CFC and PFIC can create unexpected and often significant tax consequences for businesses with international structures. Understanding how these rules apply and where risks may arise is critical before expanding or restructuring.

How We Help

We provide focused, risk‑aware advisory support, including:

Controlled Foreign Corporation (CFC) analysis

Assessing ownership, control, and attribution issues affecting US taxpayers

Passive Foreign Investment Company (PFIC) exposure reviews

Identifying potential PFIC status and associated tax and reporting implications

US investor tax planning considerations

Supporting informed decision‑making for investments and restructurings

Cross‑border structuring and compliance support

Helping align international structures with US tax requirements

Why Work With FD

Trusted advisors to US and international clients
Deep expertise in complex cross‑border tax matters
Practical, risk‑focused advice tailored to your specific circumstances

We prioritise clarity and commercial outcomes, not unnecessary complexity.

Looking For a Trusted Partner?

Speak with our team for a clear, practical view of your options and the best way forward. No jargon. No pressure. Just informed guidance.

Featured Insights

Understanding Key Terms Relevant to US Investors: CFC and PFIC

Working with US investors can help fuel growth, but it can also be tricky in terms of understanding US tax regulations. Companies based outside the US will often be asked to make representations about their PFIC or CFC status when they are looking to take on a US investor.

Learn about CFC and PFIC taxation rules, including key strategies for tax efficiency and reporting requirements to navigate complex foreign tax implications.

Expanding into the US: Tax and Accounting

For many businesses, especially in the technology sector, expanding into the US can lead to rapid growth and significant opportunities. It’s crucial to establish a solid framework from the outset to avoid costly mistakes and excessive management efforts.

Learn about tax structuring, compliance, and strategies for non-US businesses.

Optimising R&D Tax Position and CFC/PFIC Analysis for Successful Fundraising: A Case Study

To maximise its chance of effective tax compliance and retaining essential scientific talent, a university spin-out Life Sciences company needed to implement a robust vendor selection methodology, improve record keeping and ensure it was considering the complexity of US tax regulations for US citizens owning shares in passive foreign investment corporations (PFIC).

Learn how £12.5M in funding was secured by optimising R&D tax relief, managing PFIC/CFC risks and aligning with UK and US compliance.

† This is not a CPA firm.
* Assurance, attest, and audit services provided by Frazier & Deeter, L.L.C.

“Frazier & Deeter” is the brand name under which Frazier & Deeter, LLC* and Frazier & Deeter Advisory, LLC† and its subsidiary entities provide professional services. Frazier & Deeter, LLC* and Frazier & Deeter Advisory, LLC (and its subsidiary entities)† practice as an alternative practice structure in accordance with the AICPA Code of Professional Conduct and applicable law, regulations and professional standards. Frazier & Deeter, LLC* is a U.S. licensed independent public accounting firm that provides attest services to its clients. Frazier & Deeter Advisory, LLC† and its subsidiary entities provide tax and business consulting services to their clients. Frazier & Deeter Advisory, LLC† and its subsidiary entities are not licensed U.S. CPA firms.