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US single-member LLC owned by NRA

Updated today

If a non-U.S. person (nonresident alien, or NRA) owns a U.S. single-member Limited Liability Company (LLC), the owner cannot be considered self-employed. The LLC is treated as a foreign-owned U.S. disregarded entity. The tax and reporting requirements can be surprisingly extensive, even if the LLC doesn’t generate U.S.-source income or worldwide income. See How to file taxes for an LLC with no income: a comprehensive guide.

Tax filing obligations for both the LLC and the foreign owner

U.S. single-member LLC owned by the NRA treated as a foreign-owned U.S. disregarded entity (FOUSDE)

  1. EIN requirement:

    • The LLC must apply for an Employer Identification Number (EIN) using Form SS-4 and submit it via fax or mail, or apply online through the IRS website.

    • Box 10 should explain that it is for filing Form 5472.

  2. Form 5472 with Pro Forma 1120:

    • Required even if there is no U.S. trade or business or U.S.-source income.

    • Form 5472 — to report transactions between the U.S. LLC and its foreign owner (e.g., capital contributions, payments). Refer to our Guide to Form 5472: filing requirements and instructions.

    • Pro Forma Form 1120 — just the first page, with "Foreign-Owned U.S. DE" written at the top.

Deadline: April 15 (with an option to file Form 7004 for a 6-month extension to file 5472/1120. Request a non-personal extension in your TFX account).

How to file:

  • “Foreign-owned U.S. DE” should be written across the top of the Form 1120 and Form 7004.

  • ❗ Neither the extension (Form 7004) nor Form 5472 with Pro Forma 1120 can be e-filed. Both must be faxed or mailed to a specific IRS department that handles foreign-owned disregarded entities (FOUSDEs):

    • Fax (300 DPI or higher) to 855-887-7737.

    • ✉ Mail to:

    Internal Revenue Service
    1973 Rulon White Blvd
    M/S 6112 Attn: PIN Unit
    Ogden, UT 84201


Owner-level filings: When required

  1. Form W-7:

    1. If you don’t have a TIN (SSN or ITIN), apply for an ITIN using Form W-7 and mail it with your tax return.

  2. Form 1040-NR:

    • The foreign owner must file if the LLC is engaged in a U.S. trade or business or has effectively connected income (ECI).

    • If the LLC only holds passive assets or has no U.S. activity, the owner might not need to file Form 1040-NR — but filing Form 5472 is still mandatory.

  3. Withholding obligations (if applicable):

    1. If the LLC makes distributions to its NRA owner or pays U.S.-source income to other foreign persons, it may need to:

      • Withhold 30% tax (or lower treaty rate).

      • File Form 1042 and 1042-S to report payments to foreign persons.

Deadline: April 15 or June 15 (with an option to file for a 6-month extension to file personal nonresident tax return. Request a personal extension in your TFX account).

How to file: E-filing is allowed.


Common pitfalls

  • Failure to file Form 5472 carries a $25,000 penalty per year.

  • Filing Form 5472 without an EIN or mailing to the wrong address can result in rejection or penalties.

  • No Form 5472 e-filing: must be mailed or faxed to the correct Ogden, UT address.


Individual tax return preparation or tax preparation for a business?

If you have a single-member LLC based in the U.S. that you would like to be treated as a disregarded entity (DE), and you want TFX to prepare a tax return for you:

  • If you are a non-resident or NRA (not a U.S. person), answer Yes to "I am looking for tax preparation for a business or entity" in your tax questionnaire, because the IRS treats FOUSDE differently from USDE.

  • If you are a U.S. resident, then answer Yes to "I am looking for individual tax return preparation" in your tax questionnaire. You need to file a personal tax return.

A "disregarded entity" is a business structure that is separate from its owner for legal purposes, but ignored (or "disregarded") for U.S. federal income tax purposes.

  • For legal purposes: The entity exists as a separate legal person. For example, a single-member LLC can sign contracts, own property, and offer liability protection to its owner.

  • For tax purposes: The IRS ignores the entity as separate from its owner. The income, expenses, and tax obligations "pass through" to the owner's individual tax return.

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