Tax
No US-Source Income? Still File Form 5472
Even with no US-source income, a foreign-owned Delaware LLC must file Form 5472 with a pro-forma 1120. Here is why, what to report, and how to file it.
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It is one of the most common misreadings among non-resident founders: no US customers means no US filing. In reality, Form 5472 is triggered by the structure of a foreign-owned single-member LLC, not by where your revenue comes from, so even a year with zero US-source income still requires the form and a pro forma 1120. This guide explains why the requirement is structural, what genuinely dormant looks like, and why the $25,000 penalty is built to hurt anyone who skips it.
The 5472 trigger is structural, not revenue-based
Treasury Regulation § 1.6038A-1 makes foreign-owned single-member US LLCs reportable corporations by default.
The classification is structural: it does not depend on whether you earned US-source income, on transaction volume, or on whether the LLC was active during the tax year.
If the LLC exists at any point during the tax year and has a foreign owner, the obligation attaches.
Many non-resident founders assume that if their LLC sat dormant with no revenue, no filing is required. This is wrong.
A dormant Delaware LLC owned by a non-resident still owes Form 5472 plus a pro forma Form 1120.
What to file when there is no US-source income
Filings consist of two parts. First, Form 5472: report any reportable transactions between the LLC and the foreign owner during the year.
If no transactions occurred, the form is mostly empty but still required. Second, pro forma Form 1120: a stripped-down version showing the LLC name, EIN, address, and the attached Form 5472.
No tax is owed (the LLC is disregarded), but the filing must be made.
CPA fee for a no-transaction year: typically $300-$500. Much cheaper than the $25,000 penalty for non-filing.
When is the LLC actually dormant?
Many founders describe their LLC as dormant when, in fact, capital contributions, bank-fee payments, or owner distributions occurred during the year. These are reportable transactions for Form 5472.
Even a $10 bank fee paid by the owner on behalf of the LLC is a reportable transaction.
Bank statements during the tax year are the simplest reality check. If anything moved in or out, the LLC was not fully dormant for 5472 purposes.
What US-source income actually means for your LLC
Before you can decide whether your income is US-source, you need to understand how the IRS defines the term, because non-resident founders routinely guess wrong and the wrong guess leads to either needless panic or dangerous complacency.
US-source income is determined by sourcing rules tied to where work is performed and where the income-producing relationship sits, not by where the money lands or what currency it arrives in.
If you write code, design websites, build apps, or write copy from your apartment in Lagos, Manila, Karachi, or Sao Paulo, the service is performed outside the United States, so the income is foreign-source even when a US client is the one paying you.
The location of your Mercury or Wise account does not change the sourcing one bit.
Money sitting in a US bank does not magically become US-source income, and a US customer on the other end of an invoice does not convert your foreign labor into American labor.
The activity that produces the income is what gets tested, and for a founder physically working abroad, that activity happens abroad.
This distinction matters because founders consistently conflate three separate things that the tax code treats as unrelated: where the customer is located, where the bank account is held, and where the work physically happens.
For a single-member Delaware LLC owned by a non-resident who performs all the work abroad and has no US office, no US employees, no US agents, and no dependent contractors operating inside the country, the income is almost always foreign-source and not effectively connected to a US trade or business.
That usually means there is no US federal income tax on the profit at all.
But, and this is the exact point the original post drives home, the Form 5472 reporting duty exists regardless of how that sourcing analysis turns out, which is why getting the concept straight protects you from the more expensive mistake.
Keep these two questions strictly separate in your own head, because collapsing them is the root cause of nearly every error non-resident founders make here.
Question one is do I owe US tax, which depends on sourcing and whether you have effectively connected income.
Question two is do I have to file Form 5472, which depends only on whether you are a foreign owner of a US LLC during the year.
The answer to question two is yes even when the answer to question one is no tax owed, and treating those as a single combined question is precisely what walks founders into trouble.
Why the IRS built an information-only filing requirement
It can feel illogical to file a return when you owe nothing, so it genuinely helps to understand why the rule exists before you resent it.
Form 5472 is an information return, not a tax return, and that single fact reframes everything about it. Its purpose is transparency, not revenue collection.
After Treasury extended the reporting regime to foreign-owned disregarded entities, the goal was to give the IRS visibility into money moving between a US LLC and its foreign owner.
The agency wanted to close a blind spot where non-residents could route capital, loans, and payments through a US entity with essentially no paper trail, which made the structure attractive to people doing things the IRS would rather see.
By requiring an annual disclosure from every foreign-owned single-member LLC, Treasury turned an opaque structure into one the agency can at least observe, whether or not any tax is ever due.
That framing explains why your $0 of US-source income changes absolutely nothing about the obligation.
The IRS is not asking how much US tax you owe on this form, and the form has no line that computes a tax bill for a disregarded LLC.
It is asking what flowed between you and your entity during the year: capital you contributed to start the LLC, distributions you took out for yourself, loans in either direction, and reimbursements you paid or received.
Those movements happen whether or not the LLC ever sells a single thing to a US customer.
A founder in Cairo who funded the LLC with $500 of startup capital and paid the $110 Delaware formation cost through that account already has reportable transactions to disclose, even with zero revenue from anyone, anywhere on the planet.
Once you see Form 5472 as a disclosure rather than a tax bill, the rest of the compliance picture stops feeling arbitrary and starts feeling almost mechanical.
You are documenting the relationship between yourself and a US entity for an agency that has decided it wants that relationship on record.
The pro forma Form 1120 that rides along is just the cover sheet the IRS requires you to attach the disclosure to, since a disregarded LLC has no income tax return of its own to file.
You write the LLC name, the EIN, the address, and the words that flag it as a foreign-owned disregarded entity, then you staple the 5472 behind it.
There is no tax computed and none owed at that level, which is exactly why founders who expect a normal tax return are confused by how empty the whole package looks.
Effectively connected income and the trade-or-business test
The phrase that actually decides whether a non-resident owes US tax is effectively connected income, usually shortened to ECI, and learning it pays off because it cuts through most of the confusion.
ECI is income connected to a US trade or business. If you have ECI, the foreign owner files a personal US return and pays graduated US tax on that income.
If you do not have ECI, the profit passes through to you free of US federal income tax, leaving only your home-country obligations to deal with.
So the real question lurking behind the phrase no US-source income is really this: are you engaged in a US trade or business that generates effectively connected income, or are you simply a foreign person earning foreign-source income through a US entity that happens to hold your money.
Those two scenarios produce very different tax results even though they can look identical from the outside.
For most bootstrapped non-resident founders the honest answer is no, there is no US trade or business and therefore no ECI.
Selling digital products, SaaS subscriptions, freelance services, e-books, or consulting to a global audience while working entirely from abroad does not, by itself, create a US trade or business under the way these rules are generally applied.
There is no fixed place of business inside the country, no US-based staff carrying out your operations, and no dependent agent concluding contracts on your behalf within the United States.
The customers being American does not flip the switch, and neither does processing payments through a US gateway.
What matters is where the income-producing activity physically occurs, and for a founder at a desk in another country, it occurs there.
The line does get blurry in specific, identifiable situations, and those are exactly the ones worth flagging to a CPA early rather than discovering during an audit.
Holding inventory in US fulfillment warehouses, hiring a US-based employee, or maintaining a physical office in the country can each create a US trade or business and therefore generate ECI that is actually taxable.
If any of those apply to you, the comfortable no US-source income assumption may quietly stop holding, and you could owe real tax on top of the information filing.
This is why the safe move is to get your sourcing and ECI position reviewed before you file rather than after, especially in the years where your operations change shape, because the difference between no ECI and ECI is the difference between zero US tax and a graduated US tax bill on your profits.
Reportable transactions hiding in a quiet year
The original post warned that even a $10 bank fee can be a reportable transaction, and it is worth expanding that list considerably, because founders consistently and badly underestimate how many quiet movements actually count.
The seed money you wire in to open the entity is a reportable transaction. So is every distribution you take to pay yourself, no matter how small or how informal it feels.
So is a loan you make to the LLC to cover a software subscription, and the later repayment of that loan back to you.
Reimbursing yourself for the Delaware formation cost, or covering the $300 franchise tax from a personal card and then having the LLC pay you back, both count.
The pattern that catches people is that none of these feel like business activity in the ordinary sense, so a founder mentally files the year under nothing happened while the bank statement tells a different story entirely.
These transactions are reported on Form 5472 by category and by total dollar amount, aggregated across the whole year, rather than as an itemized list of every single transfer.
You do not list every coffee or every minor fee individually, but you do total the contributions, the distributions, and the amounts paid by or to the foreign owner so the IRS can see the magnitude of money moving across the owner-entity boundary.
A common real-world pattern looks like this: $1,000 contributed in January to fund the account, $300 paid out in June to cover the franchise tax through a personal card and then reimbursed, and $400 distributed in December as the founder takes some money back out.
That is three reportable categories with real dollar figures, all generated in a year the founder cheerfully describes as one where nothing happened.
The practical takeaway is to keep your personal money and your LLC money mechanically separate and to keep records as you go rather than reconstructing them under deadline pressure.
When the LLC pays its own bills directly from its own account, your reportable transactions shrink down to the genuine capital movements between you and the entity, which are easy to total.
When you constantly pay LLC expenses on personal cards and then reimburse yourself in dribs and drabs, you multiply both the reportable activity and the bookkeeping work without any benefit.
Clean separation through a dedicated business account at Mercury, Wise, Relay, Lili, or Payoneer makes the year-end filing far simpler, because the year is already documented in one place by the time your CPA asks for it.
How to obtain the EIN you need before filing
You cannot file Form 5472 without an EIN, and non-resident founders without a Social Security Number obtain one through a specific path that trips a lot of people up, so it is worth walking through carefully.
The EIN is free directly from the IRS, full stop, despite the many services that try to charge a fee for what amounts to filling out one form.
As a non-resident without an SSN or an ITIN, you cannot use the instant online application the IRS offers to US persons, because that system requires a taxpayer identification number it can validate.
Instead you complete Form SS-4 and submit it by fax or by mail, writing the word foreign on the responsible-party SSN line where a US applicant would otherwise put their number.
That single word is what tells the IRS to process the application through the non-resident channel rather than rejecting it for a missing identifier.
The realistic timeline for the fax route is roughly 8 to 10 business days to receive your EIN confirmation, sometimes faster and occasionally slower depending on IRS workload at the time you submit.
Mail is meaningfully slower and far less predictable, so most non-resident founders fax. The EIN belongs to the LLC permanently once issued, so this is a one-time exercise you never repeat for that entity.
Getting it early matters more than founders expect, because the EIN gates not only your tax filing but also your bank account opening, since banks will not finish onboarding an entity that lacks one.
A missing EIN at filing time is one of the most common reasons founders blow through the Form 5472 deadline, having assumed the number would arrive faster than it did.
One detail that saves real grief later is consistency across documents.
Make sure the responsible party named on the SS-4 is you, the actual owner of the LLC, and that the entity name and address match your Delaware formation documents exactly, character for character.
Mismatches between the SS-4, the formation paperwork, and the later Form 1120 create processing delays and occasionally bounce filings back to you at the worst possible time.
Confirm that the EIN confirmation letter, often issued as the CP 575, is stored somewhere safe and backed up, because your CPA will need that number every single year, and getting the IRS to reissue confirmation of a lost EIN is a slow and tedious process you do not want to repeat under deadline.
The $300 franchise tax is a separate obligation entirely
Non-resident founders frequently merge two unrelated deadlines in their minds and then panic when they realize they only handled one of them, so it pays to separate them cleanly and permanently.
The Delaware franchise tax is a flat $300 per year and is due by June 1.
It is a state fee for the privilege of keeping your LLC in good standing in Delaware, and it has nothing whatsoever to do with income, profit, revenue, or any US-source analysis.
A completely dormant LLC with zero revenue owes the exact same $300 as one earning six figures, because this is a flat fee and not an income tax.
The amount never scales with your earnings, which is precisely why it confuses founders who expect anything labeled tax to depend on how much they made during the year.
Form 5472, by contrast, is a federal information filing tied to your federal tax deadline, generally April 15 with extension options available if you need more time to assemble the figures.
So in a typical year you face two distinct events on two different calendars run by two different governments: the Delaware franchise tax by June 1 paid to the state, and the federal Form 5472 plus the pro forma Form 1120 sent to the IRS around the April deadline.
Confusing the two leads founders to believe that paying the $300 somehow satisfies their federal duty, which it does not in any way.
Paying the franchise tax keeps the entity alive and in good standing at the state level and accomplishes precisely nothing for the IRS, just as filing the 5472 does nothing to keep Delaware happy.
Missing the franchise tax carries its own distinct consequences that compound over time.
Delaware adds a $200 penalty plus interest on the unpaid amount, and prolonged non-payment can push the LLC into a non-good-standing status that complicates your banking, blocks you from obtaining a certificate of good standing, and can eventually lead toward administrative trouble for the entity.
So treat June 1 and your federal filing date as two completely separate, non-negotiable entries on your calendar, ideally with their own reminders weeks ahead.
Both are unavoidable for a non-resident-owned Delaware LLC, regardless of whether you earned a single dollar of US-source income, and neither one excuses or covers the other.
Building a compliance calendar a non-resident can actually follow
Because the deadlines come from two different governments and sit months apart on the calendar, the founders who reliably stay compliant treat the year as a fixed checklist rather than trusting their memory to surface the right date at the right moment.
A workable annual rhythm looks roughly like this. In the first quarter, gather the prior-year bank statements and tally up your reportable transactions for Form 5472 so the raw material is ready.
By the federal deadline in April, file Form 5472 together with the pro forma Form 1120, using an extension if your CPA needs additional time to finish.
By June 1, pay the $300 Delaware franchise tax to the state. Late in the year, reconcile your books so the next cycle starts from a clean position rather than a tangle of half-remembered transfers.
Written down this way, the obligations stop feeling like a vague threat and become four concrete tasks.
Time zones and physical distance make all of this harder than it sounds for someone managing the entity from another continent entirely.
The IRS deadline does not shift to accommodate your location or your local holidays, and the Delaware franchise tax portal does not send most founders a reminder before the date arrives.
Set calendar alerts weeks ahead of each deadline rather than on the day itself, so you have genuine room for an international bank transfer that takes several days to clear, or for a CPA who emails back asking for one more document you have to dig up.
A wire from your home country can take days to settle, which becomes a real problem when a US deadline is bearing down and you started the payment too late to leave any margin.
If you run more than one entity, or you are juggling this alongside a full-time job and a life in a different country, write the dates down in a shared document with your CPA and confirm explicitly who owns each task.
The single most common cause of the $25,000 penalty is not stubborn refusal to comply and not an inability to afford the few hundred dollars it costs.
It is a founder who quietly assumed someone else was handling the filing, or who simply forgot a date that lives in a foreign tax calendar they rarely think about during the rest of their year.
Clear ownership of each deadline, written somewhere you and your CPA both see, removes that failure mode almost entirely.
Why the $25,000 penalty is structured to hurt
The penalty for failing to file a required Form 5472 is $25,000 per form, and understanding why it is set so high is what finally makes founders take it seriously instead of treating the filing as optional paperwork.
This penalty is not a percentage of tax owed, which is exactly what makes it so dangerous for non-resident founders who have no US-source income and therefore no US tax bill to anchor it against.
A founder who owes $0 in US tax and skips the form still faces the full $25,000, because the penalty was never tied to tax in the first place.
The filing is informational, and Congress understood that if the penalty for skipping an information return were a fraction of tax owed, a zero-tax founder would have no reason at all to file.
So they made the penalty flat, large, and indifferent to your profit, which is the only design that actually compels compliance from people who owe nothing.
The penalty can also compound in ways that turn a small oversight into a serious financial problem.
Each missing year is its own separate $25,000 exposure, and the IRS can assess for several open years at once when it catches the gap.
A founder who ignored the requirement for three years could be staring at $75,000 in penalties on an entity that never earned a dollar of US-source income and never owed a dollar of US tax.
After the IRS sends a notice demanding the missing forms, continued failure to file can add still further amounts on top.
This is the precise mechanism by which a forgotten annual filing on a quiet, dormant LLC quietly grows into a five-figure or larger problem that dwarfs everything the business ever earned.
The genuinely reassuring side is that the cost of staying compliant is trivial when set against this exposure, and the math is not close.
A CPA preparing Form 5472 and the pro forma Form 1120 for a no-transaction or low-transaction year typically charges a few hundred dollars for the whole package.
Even the one-time $297 formation cost and the recurring $300 franchise tax are small, predictable line items next to a single $25,000 penalty, let alone a stacked one.
When you lay the few hundred dollars of annual compliance beside the $25,000 downside, the rational choice is obvious: file every single year, even when the form is almost entirely blank, because the blank form costs you almost nothing and the missing form can cost you more than the business is worth.
If you already missed a year, what to do next
Plenty of non-resident founders discover this requirement long after forming the entity, sometimes a full year or two into running it, and their first reaction is to assume the situation is hopeless and the penalty is already locked in.
It is not hopeless, but the genuinely worst move available to you is to keep ignoring it once you know.
The IRS does have reasonable-cause relief for situations like this, and late-filing the missing forms with a clear, honest explanation generally produces a far better outcome than sitting still and waiting for a penalty notice to land in your mailbox.
The penalty is assessable, yes, but reasonable-cause abatement exists specifically for founders who can show they acted in good faith and corrected the omission promptly once they actually understood the disregarded-entity reporting duty existed at all.
The practical path forward is concrete and worth following in order. Engage a CPA who is experienced with non-resident-owned LLCs specifically, not a generalist who has never seen a Form 5472.
Reconstruct the reportable transactions for each missed year from your bank statements, which is exactly why keeping those statements matters.
Then file the delinquent Forms 5472 with a pro forma Form 1120 for each missed year, attaching a reasonable-cause statement to each.
That statement should be honest and specific about why the filing was missed, for example that you were a first-time foreign founder genuinely unaware that a US-formed disregarded entity carried any annual federal reporting obligation.
Vague or evasive excuses fare measurably worse with the IRS than a candid, dated timeline of what you knew and when you acted on it.
Whatever you do, do not try to quietly skip over the missed years and only file going forward, hoping the gap simply goes unnoticed.
If the IRS later examines the entity for any reason, an unexplained gap in filings looks considerably worse than a voluntary, documented correction that you initiated yourself.
Coming forward before the IRS contacts you is consistently treated more favorably than scrambling to respond after a penalty notice has already been issued, because the agency can see the difference between someone fixing their own mistake and someone caught.
Treat a discovered omission as something to fix during this filing season, with a CPA and a reasonable-cause statement, rather than something to defer to next year and hope away.
The BOI report and why your US LLC is now exempt
A separate filing scared a great many non-resident founders over the past couple of years: the beneficial ownership information report, known as the BOI report, under the Corporate Transparency Act.
This one is worth clarifying carefully, because it is extremely easy to confuse with Form 5472, and the rules around it changed in a way that older guides have not caught up with.
Under the FinCEN interim final rule issued on March 26, 2025, entities formed in the United States, which includes your Delaware LLC, are exempt from the BOI reporting requirement entirely.
The reporting obligation was narrowed so that it now reaches foreign entities registering to do business in the US, rather than domestically formed entities like a standard Delaware LLC owned by a non-resident.
What that means in plain terms is that a non-resident-owned Delaware LLC does not file a BOI report at all.
If you read an older guide written before that rule took effect, it may confidently instruct you to file beneficial ownership information with FinCEN within some fixed window after formation, and to keep it updated when ownership changes.
For a US-formed LLC, that entire instruction is now outdated and you should not act on it.
The critical thing is to not confuse this exemption with Form 5472, which is completely unchanged and still required every year.
The BOI exemption removes one filing from your list, and it touches nothing about your federal tax-information duty, which lives in an entirely separate part of the law administered by a different agency.
Keep the two firmly and permanently separate in your mind so that you neither file something unnecessary nor skip something that remains mandatory.
On the BOI side: a report to FinCEN is not required for your US-formed Delaware LLC, and has not been since the March 26, 2025 interim final rule reshaped who must file.
On the Form 5472 side: the form plus the pro forma Form 1120 still goes to the IRS every single year that you own the entity, even with no US-source income and no US tax owed.
Treating one exemption as if it somehow covered both obligations is exactly the kind of mix-up that produces a $25,000 surprise, because a founder hears US LLCs are now exempt, assumes it applies across the board, and quietly stops filing the one thing that was never exempt to begin with.
Banking, bookkeeping, and the records the filing depends on
The quality of your Form 5472 filing depends almost entirely on the quality of your records, and for a non-resident founder that quality starts with one decision: opening a dedicated business account and routing everything through it.
Options that commonly accept non-resident-owned Delaware LLCs include Mercury, Wise, Relay, Lili, and Payoneer, each with its own onboarding quirks but all workable for a foreign founder with a formed LLC and an EIN.
Running every contribution, every distribution, and every expense through one business account, rather than scattering them across personal cards in your home country, gives you a single statement at year-end that maps almost directly onto the reportable transactions Form 5472 asks for.
That one decision quietly removes most of the guesswork and reconstruction that otherwise makes the annual filing miserable.
Good bookkeeping for a small entity like this does not require expensive accounting software or a complicated setup.
A simple spreadsheet that logs each transfer between you and the LLC, with a date and a category marking it as a contribution, a distribution, a loan, or a repayment, is entirely sufficient for most no-revenue or low-revenue non-resident founders.
The point is not to produce audited financial statements. The point is to capture the owner-to-entity movements that Form 5472 actually reports, in a form you can hand over without thinking hard about it.
When your CPA asks for the year, you give them one clean bank statement and one short ledger, instead of sitting down to reconstruct half-remembered transfers from across twelve months and several payment methods.
Banking also intersects with timing in ways non-resident founders routinely underestimate, and the intersection bites at the worst moment.
Opening the account itself can take days or even weeks of review depending on the provider and your country of residence, and you need the EIN in hand first, which on its own takes roughly 8 to 10 business days through the SS-4 fax route.
Stacking those waiting periods means a founder who starts the whole process late can find themselves at a filing deadline with a bank account that just barely opened and no clean records behind it.
The fix is to sequence everything early and in order: form the LLC, get the EIN, open the business account, and then keep the records flowing from day one, so that the annual Form 5472 is a quiet formality rather than a frantic scramble against a deadline you cannot move.
Common myths that lead founders to skip filing
It genuinely helps to name the specific false beliefs that lead non-resident founders to miss this filing, because seeing your own assumption written plainly on a list is often what finally changes the behavior.
Myth one: my LLC made no money this year, so there is simply nothing to file.
The filing is triggered by the structure of the entity, not by profit, so a zero-revenue year still requires a complete Form 5472 with its pro forma Form 1120 attached.
Myth two: I earned no US-source income, so the IRS has no interest in me and nothing to report on.
The information return exists precisely to document the foreign-owner relationship regardless of how the sourcing of your income works out, which is the whole reason the original post emphasizes the structural trigger so heavily.
Myth three: paying the $300 Delaware franchise tax covers my federal duty, so I am all set once that is done.
The franchise tax is a state fee for keeping the entity in good standing and does nothing whatsoever for the IRS, as a separate section here explains in detail.
Myth four: my formation service handles all of my filings forever, so I do not need to think about any of this.
Most formation packages cover the initial setup and perhaps a registered agent, but not your recurring annual federal tax-information filing, which falls squarely on you or the CPA you hire.
Myth five: since US LLCs are now exempt from the BOI report, surely all of my federal filings have become optional.
The BOI exemption is entirely unrelated to Form 5472 and changes nothing about your obligation to file it every year.
The thread running through every single one of these myths is the same buried assumption: that no tax owed must mean no filing owed.
For a foreign-owned single-member Delaware LLC, those are two different questions with two different answers, and the gap between them is where founders fall.
You can owe exactly zero US tax and still owe the IRS a complete Form 5472 and a pro forma Form 1120 every year you hold the entity.
Internalizing that one separation, between owing tax and owing a filing, prevents very nearly every costly mistake that non-resident founders make on this requirement, because almost all of those mistakes trace back to collapsing the two ideas into one comfortable but wrong conclusion.
Putting it together as a non-resident founder
Step back from the individual rules and the whole picture turns out to be considerably simpler than the parts suggest.
As a non-resident who owns a single-member Delaware LLC and performs all of the work abroad, you most likely have no US-source income, no effectively connected income, and therefore no US federal income tax due on your profit at the entity level or as the owner.
Your home country still taxes you according to its own rules, and that obligation sits entirely outside this analysis and is not something the US filings address or replace.
What you do owe the United States is a small, well-defined set of filings that exist to document the entity and your relationship to it, rather than to collect any tax from a business that produces no US tax in the first place.
Those filings are predictable, inexpensive, and few in number once you lay them out.
Form 5472 with a pro forma Form 1120 goes to the IRS each year you own the entity, around the April federal deadline, reporting the capital you put in and the distributions you take out across the owner-entity boundary.
The flat $300 Delaware franchise tax goes to the state by June 1 to keep the LLC in good standing, separate from anything federal.
You obtained your free EIN exactly once, through the SS-4 fax process that takes roughly 8 to 10 business days for a non-resident without an SSN.
You keep clean records through a dedicated business account at a provider like Mercury, Wise, Relay, Lili, or Payoneer.
And you do not file a BOI report at all, because US-formed entities have been exempt since the FinCEN interim final rule of March 26, 2025.
The discipline this whole thing actually demands is calendar discipline, not deep tax expertise, which is good news for a founder running a business from another country.
Set the two deadlines, keep the records flowing month by month, and either file the forms accurately yourself or hand a clean statement to a CPA who genuinely knows non-resident LLCs.
Doing exactly that for a few hundred dollars a year keeps you safely clear of the $25,000 penalty and lets you run the business without a compliance cloud hanging over every decision.
No US-source income does not mean no obligations to the United States. It means a lighter, clearly bounded set of obligations that a prepared founder handles each year without stress, drama, or surprise.
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