For residents of Ireland who own a US LLC

US LLC Owned From Ireland: Form 5472, Taxes and Filing

Owners in Ireland often learn about Form 5472 late. Here is what the IRS expects from your US LLC each year, which tax ID to report, and how the treaty with Ireland affects you.

Form 5472Pro forma 1120Treaty: yesW-8BENBE-13

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Quick answer

Does a resident of Ireland 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 Ireland 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 Ireland, which affects how profits and US-source payments are taxed, not whether Form 5472 is due.

Prepared by Illuminous Accounting · Sources checked November 11, 2026

At a glance

Yearly US filing: Form 5472 with a pro forma Form 1120
US tax treaty with Ireland: Yes, per the IRS treaty list
Your home tax ID: Your Personal Public Service Number (PPS No), which the Revenue Commissioners use to identify taxpayers
Currency: Convert euros to US dollars; the form is in US dollars
Fees: See our Form 5472 filing service page, or request a quote

Is there a US tax treaty with Ireland?

Yes: the IRS lists Ireland 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 Ireland; 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 yearly US filings for an LLC owned from Ireland

Here is the yearly list for a single-member LLC whose only owner lives in Ireland.

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.

Documents for owners living in Ireland

Most of what goes into the filing comes from the LLC's own records. The parts that come from you, as an owner living in Ireland, are short.

Item	For an owner in Ireland
Identity	Passport and current home address
Tax ID	Your Personal Public Service Number (PPS No), which the Revenue Commissioners use to identify taxpayers
Money in and out	Statements showing what you paid into the LLC and took out during the year, including amounts in euros
Company papers	Articles of organization and the IRS EIN letter

For a resident of Ireland, this is usually your Personal Public Service Number (PPS No), which the Revenue Commissioners use to identify taxpayers (OECD tax ID sheet).

Your taxes in Ireland

Irish founders use a US LLC to sell software and services into the US and to contract with US clients in a US entity.

How the LLC's profit is taxed in Ireland is decided under the tax rules of Ireland, which can treat a US LLC differently from the way the IRS does. Check that with a tax adviser in Ireland. We handle the US side and can give your adviser the US figures and filings.

Fees and next step

Owners in Ireland 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 law references for owners in Ireland

Plain-language summaries; follow the links for the official text. Article numbers are from the treaty text on irs.gov.

Treaty

The IRS lists the 1997 income tax treaty, signed July 28, 1997, amended by an amending convention listed for 1999. General effective date (IRS Table 3): treaty Jan. 1, 1998 (IRS treaty documents for Ireland; treaty text; IRS Table 3).
Article 4 (Residence), 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 23 (Limitation on Benefits), which sets the tests a resident must meet to claim benefits.
Article 24 (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 Ireland 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.

Common questions

Does a resident of Ireland 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 Ireland do you need from me?

Your Personal Public Service Number (PPS No), which the Revenue Commissioners use to identify taxpayers. The IRS asks for the same foreign tax ID every year.

Does the United States have a tax treaty with Ireland?

Yes. Ireland 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 Ireland 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.

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.

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