For residents of Bulgaria who own a US LLC
US LLC Owned From Bulgaria: Form 5472, Taxes and Filing
You live in Bulgaria and own a US LLC. Each year it files Form 5472 with a pro forma Form 1120, even with no US income, and the US has an income tax treaty with Bulgaria. This page covers what to file, what to enter as your foreign tax ID, and what the treaty position means for you.
Quick answer
Does a resident of Bulgaria who owns a US LLC have to file with the IRS?
Yes, if the LLC had a reportable transaction with you, and forming and funding it counts. A single-member US LLC owned by a resident of Bulgaria files Form 5472 with a pro forma Form 1120 each year, usually by April 15 for a calendar year, even with no income. The US has an income tax treaty with Bulgaria, which affects how profits and US-source payments are taxed, not whether Form 5472 is due.
At a glance
- Yearly US filing
- Form 5472 with a pro forma Form 1120
- US tax treaty with Bulgaria
- Yes, per the IRS treaty list
- Your home tax ID
- The tax identification number issued to you in Bulgaria
- Currency
- Convert Bulgarian leva to US dollars; the form is in US dollars
- Fees
- See our Form 5472 filing service page, or request a quote
The yearly US filings for an LLC owned from Bulgaria
Here is the yearly list for a single-member LLC whose only owner lives in Bulgaria.
- Every year with a related-party transaction: Form 5472, attached to a pro forma Form 1120. Forming the LLC, funding it and taking money out all count (IRS instructions). The LLC usually owes no US income tax as a disregarded entity; this is an information return.
- Once, soon after you start: the BE-13 survey to the Bureau of Economic Analysis, generally within 45 days of a foreign person setting up or buying a US business (BEA rule).
- Every year, to the state: whatever the formation state charges; US LLC annual fees by state lists them.
- Only sometimes: Form 1040-NR, when the LLC earns income effectively connected with a US trade or business (IRS).
Missing Form 5472 costs US$25,000 per failure, and a substantially incomplete form counts as not filed.
What we need from an owner in Bulgaria
To prepare the filing for an owner in Bulgaria, we ask for:
- Your passport and your home address in Bulgaria
- Your tax ID: The tax identification number your home tax authority in Bulgaria issued to you, if you have one (IRS).
- The LLC's formation documents and EIN letter
- Bank and payment account statements for the year, so every transfer between you and the LLC can be listed, converted from Bulgarian leva where needed
The IRS wants all amounts in US dollars and the same tax ID used every year (IRS).
Is there a US tax treaty with Bulgaria?
Yes: the IRS lists Bulgaria among the countries with a US income tax treaty (IRS treaty list). The treaty does not remove Form 5472. What it can change is how much US tax applies to the LLC's profit and to payments you receive.
| Question | With the treaty | Source |
|---|---|---|
| Is the LLC profit taxed in the US? | Generally only the part attributable to a US permanent establishment, such as an office or dependent agent in the US | Form 8833 |
| Do I have to tell the IRS I rely on that? | Yes, on Form 8833 with the return; not disclosing costs US$1,000 | Form 8833 |
| Can I get lower withholding on US dividends, interest or royalties? | You can claim it on Form W-8BEN by naming Bulgaria; otherwise 30% generally applies | W-8BEN, Pub 515 |
Treaty benefits depend on the exact article and on whether you qualify under it, so we check the treaty text before relying on it.
The Bulgarian side of your LLC
Bulgarian developers and software companies use a US LLC to sell services and products in US dollars.
The US view of the LLC does not decide how Bulgaria sees it. Ask a tax adviser in Bulgaria how the LLC and its profit are treated there; we prepare the US filings and share the figures your adviser needs.
Fees and next step
Owners in Bulgaria are handled exactly like owners anywhere else: Form 5472 with the pro forma Form 1120, or the annual package for a single-member LLC, prepared and signed by Gurleen Kaur, CPA licensed in British Columbia and Washington State. Fees are on our Form 5472 filing service.
See our Form 5472 filing service, the annual compliance package and which state to form in.
Treaty and US law sources
Where each rule on this page comes from, for an owner resident in Bulgaria.
Treaty
- The IRS lists the 2007 income tax treaty. General effective date (IRS Table 3): treaty Jan. 1, 2009 (IRS treaty documents for Bulgaria; treaty text; IRS Table 3).
- Article 4 (Resident), which decides who counts as a resident for treaty benefits.
- Article 5 (Permanent Establishment), which defines a US permanent establishment.
- Article 7 (Business Profits), under which business profits are taxed in the US only if attributable to a permanent establishment.
- Article 10 (Dividends), on dividends.
- Article 11 (Interest), on interest.
- Article 12 (Royalties), on royalties.
- Article 21 (Limitation On Benefits), which sets the tests a resident must meet to claim benefits.
- Article 22 (Relief From Double Taxation), on relief from double taxation.
- Treaty benefits for income earned through a fiscally transparent entity, such as a single-member LLC, are decided under section 894 and Treas. Reg. section 1.894-1(d) (IRS Pub 515, Form 8833).
US law
- Form 5472: Internal Revenue Code section 6038A and Treas. Reg. section 1.6038A-1; final regulations T.D. 9796 treat a foreign-owned US disregarded entity as a corporation for this purpose (IRS Form 5472 instructions).
- US trade or business and effectively connected income: Code sections 864 and 871 (IRS Pub 519).
- Treaty disclosure: Code section 6114, Treas. Reg. section 301.6114-1, and the section 6712 penalty (IRS Form 8833).
- BE-13: 15 CFR 801.7 (eCFR).
The tax law of Bulgaria itself also applies to you; check it with a local adviser.
Owners in other countries
Every country page uses the same US rules with that country's treaty status and tax ID. See all of them on US LLC tax by country.
- The Netherlands
- Turkey (Turkiye)
- Romania
- China
- Argentina
- Brazil
- The United Kingdom
- Germany
- India
- Pakistan
- The United Arab Emirates
- South Africa
- Australia
- Panama
- Peru
- Greece
- Italy
- Spain
- France
- Nigeria
- Mexico
- The Philippines
- Poland
- Portugal
- Israel
- Japan
- South Korea
- Thailand
- Ireland
- Switzerland
- Sweden
- Austria
- Belgium
- Denmark
- Norway
- New Zealand
- Singapore
- Hong Kong
- Malaysia
- Colombia
- Kenya
- Ghana
- Saudi Arabia
- Vietnam
- Chile
- The Czech Republic
- Finland
- Iceland
- Estonia
- Latvia
- Lithuania
- Slovakia
- Slovenia
- Indonesia
- Ukraine
- Egypt
- Bangladesh
- Morocco
- Sri Lanka
- Cyprus
- Malta
Common questions
Does a resident of Bulgaria have to file Form 5472 for a US LLC?
Yes, if the single-member LLC had a reportable transaction with you in the year, which includes forming it and putting money in. It is filed with a pro forma Form 1120. The penalty for not filing is US$25,000.
Which tax ID from Bulgaria do you need from me?
The tax identification number issued to you in Bulgaria. The IRS asks for the same foreign tax ID every year.
Does the United States have a tax treaty with Bulgaria?
Yes. Bulgaria is on the IRS list of US income tax treaties. The treaty can limit US tax on business profits to profits attributable to a US permanent establishment, a position disclosed on Form 8833, and lets you claim treaty rates on Form W-8BEN.
Does an LLC owner in Bulgaria file a US income tax return?
Usually only Form 5472 with the pro forma Form 1120 is filed. A Form 1040-NR is needed if the LLC has income effectively connected with a US trade or business, and the treaty may limit US tax to profits attributable to a US permanent establishment.
Sources
Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.
- IRS: United States income tax treaties, A to Z
- IRS: Instructions for Form 5472
- IRS: Form 5472
- IRS: Form 8833, treaty-based return position disclosure
- IRS: Instructions for Form W-8BEN
- eCFR: 15 CFR 801.7 (BE-13 reporting requirement)
Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated November 11, 2026. This page is general information, not tax or legal advice for your situation.
Related guides: Form 5472 filing service, Annual compliance package, US LLC tax by country.
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