No, the IRS won't view the UK company as US in any way. You are the majority owner, but it is still a foreign corporation. The only way it would be taxable in the US is if it actually started doing business here through a permanent establishment.
You will have many issues that you need to be aware of, however. First, you have to track the Earnings & Profits as well as the taxes each year, and keep them in a "pool". If the UK company ever pays a dividend
to you, you will have both a dividend as well as a "deemed dividend" in the amount of the taxes that were in the pool.
For example, if the company earns $10, $15, and $25 after tax for its first three years, and it paid taxes in each of the years in the amount of $3, $5, and $8, there would be $50 in the earnings "pool" and $16 in the "tax" pool. If the company then paid a $20 dividend, it would be paying out $20/$50, or 40% of the earnings pool, so there would be a "deemed dividend" of 40%, or $6.40 of taxes from the "tax pool". So your total dividend would be $26.40 with $6.40 "Gross-up" of foreign taxes that you could use as a foreign tax credit
on Form 1116
You also have to be careful about borrowing any money from the UK company. If you borrow anything, and have not repaid it by 12/31 of any tax year, it is also a "deemed dividend" or Subpart F income, under Internal Revenue Code
§956. So if you borrowed $50 from the UK company in August 2014, and had not paid it back by December 31, 2014, you would be considered to have a $50 dividend. It would come with a gross-up of foreign taxes as well.
As you can see, owning a foreign company can be complex. But follow the rules
starting early, and you can be a step ahead, and make it not that difficult. I am not sure what the new rules are as far as customer contact, but I believe we can now offer additional services, so if any of this comes to pass, you could contact me if you wish and we could help you with this.
I hope this answers your questions. If you have any more, ask away! I know I may have opened a can of worms, but I like you to be aware of what future implications you might have before they happen. If you have found this helpful, please rate me highly.