Question 1

I'm a Ukrainian citizen but actually live in the US — am I a Ukrainian tax resident?

Accepted Answer

Not necessarily. Under Ukrainian law, a Ukrainian tax resident is someone with center of vital interests in Ukraine, or who spent >183 days in Ukraine during the year. If you permanently live in the US (Green Card, visa, substantial presence), you're likely a US tax resident, not Ukrainian. Then CFC rules don't apply to you. Verify your status — critical. Dual residency cases use the Tax Treaty tie-breaker rule.

Question 2

What's a «living minimum» and why a 268,400 UAH penalty?

Accepted Answer

Living minimum (LM) is a base unit in Ukrainian law to which penalties and benefits are tied. For 2026, LM for working-age persons = 2,684 UAH. Penalty for not filing the CFC Report = 100 LM = 268,400 UAH (~$6,400 at 42 UAH/USD). Penalty for not filing the acquisition-of-control notice = 300 LM = 805,200 UAH (~$19,200). Serious, don't ignore.

Question 3

I have a Wyoming LLC with one member (me). Does Type A exemption apply?

Accepted Answer

Likely NO. By default, single-member LLC = disregarded entity for IRS. This means LLC pays no federal corporate tax — it passes to your personal US tax return (1040 if US resident or 1040-NR if NRA). At LLC level the rate = 0%. Type A requires ≥13% effective rate at corporate level → doesn't work. Solution: file Form 8832 and make C-Corp election — LLC starts paying 21% federal tax → Type A activates → no tax in Ukraine. But C-Corp creates double taxation when you later distribute dividends.

Question 4

How will Ukraine's tax service find out I have a US LLC?

Accepted Answer

Several channels: 1) FATCA — the US and Ukraine exchange account information. If your LLC has a US bank account tied to a Ukrainian resident — banks report. 2) CRS (Common Reporting Standard) — global tax info exchange Ukraine participates in. 3) Self-reporting — Ukrainian banks ask about foreign accounts and companies when opening accounts. 4) Property declaration — mandatory annex to annual declaration (if you have income or property). Hiding is impossible, easier to declare.

Question 5

If my LLC had a net loss for the year — do I still need to file the Report?

Accepted Answer

YES. CFC Report is filed regardless of LLC profit or loss. Ukrainian tax on loss = 0 (no negative taxable base), but ownership fact must be declared. Otherwise 268,400 UAH penalty. Loss can be carried forward inside the LLC, but for Ukrainian purposes each year is evaluated separately.

Question 6

Can I credit US tax I paid on my share of LLC profit?

Accepted Answer

Yes. Ukraine-US Tax Treaty (1994) allows crediting tax paid in one country against tax in the other. If your LLC is pass-through (disregarded/partnership) — you pay US tax on your share of profit via 1040/1040-NR. This US tax can be credited against Ukrainian PIT on the same profit. Required: US tax return (1040 or 1040-NR) + W-2/1099/Schedule K-1 + effective tax rate calculation. If your LLC = C-Corp — 21% federal corporate tax is credited. In practice the credit often fully covers Ukrainian tax, leaving only the 1.5% military fee and possibly a small difference.

CFC Report 2026 — calculate Ukrainian tax on your US LLC

TL;DR

Your LLC's tax classification

Frequently asked questions