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CFC Calculator · Controlled Foreign Company
CFC Report 2026 — calculate Ukrainian tax on your US LLC
Ukrainian tax residents with a stake in a US LLC must file a CFC Report by May 1. Failure to file = 268,400 UAH (~$6,400) penalty. This calculator shows: are you a controller, does an exemption apply, what's the PIT + military fee you owe.
TL;DR
A Ukrainian tax resident with ≥25% ownership in any foreign company (or ≥10% if another Ukrainian owns ≥50%) is a CFC controller. The CFC Report is mandatory, filed with the annual income/property declaration by May 1 of the following year.
By default, a single-member US LLC = disregarded for IRS = pays 0% corporate tax in the US → fails Type A exemption (which requires effective tax rate ≥13%) → in Ukraine you pay 18% PIT + 1.5% military fee on undistributed LLC profits.
C-Corp election (Form 8832) changes this: LLC pays 21% federal tax → Type A works → no Ukrainian tax (but distributed dividends still get 9%+1.5%).
Type B exemption: if total annual income of all your CFCs <€2M — no tax, but the Report is still mandatory.
📅 Updated: May 22, 2026
Your LLC's tax classification
How your LLC is classified for the IRS — this determines whether it pays US corporate tax and whether Ukrainian Type A exemption works.
Frequently asked questions
CFC Report for Ukrainian residents with a US LLC
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.
I'll help with your CFC Report
If you're a Ukrainian resident with a US LLC — I handle CFC Report preparation and filing + annual declaration. Experience with US-Ukraine cross-border clients.
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