One wrong assumption. Five jurisdictions of compounding.
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The assumption at filing time that the US LLC would hold the IP was made in one meeting.
1
Year two: the German subsidiary is paying IP licenses to the US LLC. Transfer pricing rules now apply. Nobody told the German tax authority that structure yet.
2
Year three: UK expansion adds a Ltd. The IP flow now needs a multi-country transfer pricing study. Your US attorney has not done one of those.
3
Year four: a potential acquirer looks at the structure and sees four siloed entities with untested IP migration paths. They discount the offer by 18%.
The assumption at filing time was correct.
The context around it was not yet built.
This is the pattern, not the exception. Most cross-border founders discover the structural gap when money tries to move across it.
· The price of one uncoordinated decision ·
The cross-border premium for structural coordination is $50K in year one.
The cross-border tax for not doing it is $500K+ in year five.