Ukrainian Business Entering the US Market: Legal and Tax Structuring and Compliance

Nataliia Strutovska

Citation: Nataliia Strutovska, "Ukrainian Business Entering the US Market: Legal and Tax Structuring and Compliance", Universal Library of Business and Economics, Volume 02, Issue 04.

Copyright: This is an open access article distributed under the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.

Abstract

Within the framework of the study, a comprehensive academic and applied analysis of the legal, tax, and regulatory instruments ensuring the integration of Ukrainian companies into the economic system of the United States of America was conducted. The analytical perspective is shaped on the basis of practice-oriented expertise in the field of international tax planning, relying on a comparable understanding of the Ukrainian and U.S. legal orders. The work summarizes empirical materials from recent years, including updated indicators of business relocation and the dynamics of exports of IT services; in parallel, it provides a detailed examination of U.S. legislative changes that entered into force in Q1–Q2 2025. A central place is given to the FinCEN temporary final rule of March 2025, which substantially transformed the architecture of corporate transparency, as well as to the establishment of the United States–Ukraine Reconstruction Investment Fund (USURIF) in April 2025 as a significant institutional element of the investment infrastructure. As the final result, a scientifically substantiated methodology for selecting a jurisdiction for incorporation is formulated; approaches to reducing the tax burden within the GILTI and Section 367(d) IRC regimes are described; and mechanisms for counteracting banking de-risking are systematized.


Keywords: Entry into the U.S. Market, Corporate Structuring, FinCEN BOI Reporting, International Tax Planning, GILTI, Section 367(d) IRC, Banking De-Risking.

Download doi https://doi.org/10.70315/uloap.ulbec.2025.0204009