US company tax-resident in the UK

[stephen2.0]

Hi,

We have an internet company that is managed and controlled in the UK. We want to create a US company to make it easier for US clients to do business with us. All services are provided in the UK and we have nothing in the US only the Bank and Company.

A tax expert told me that US looks at where the company is incorporated to determine if it's taxed in the US. However i have read that only if the US company has ECI (Effective connected Income) then it will be liable to US tax. If its not engaged in business or trade in the US then it pays taxes in the UK.

Is this correct?

[AmanSood]

as the business is managed/controlled from the UK then HMRC would treat the US company as UK resident for corporation tax purposes and tax the profits in the UK.