For residents of Norway who own a US LLC
US LLC Owned From Norway: Form 5472, Taxes and Filing
Owners in Norway 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 Norway affects you.
Quick answer
Does a resident of Norway 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 Norway 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 Norway, 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 Norway
- Yes, per the IRS treaty list
- Your home tax ID
- Your national identity number, or a D-number if you were given one as a foreign national
- Currency
- Convert Norwegian kroner to US dollars; the form is in US dollars
- Fees
- See our Form 5472 filing service page, or request a quote
What a US LLC owned from Norway files each year
A US LLC with a single foreign owner is a disregarded entity for income tax, but the IRS treats it as a corporation for one purpose: reporting its dealings with its owner. That is why an owner in Norway with no US customers, no US office and no profit can still owe a US filing every year.
| Filing | When it applies | Source |
|---|---|---|
| Form 5472 with a pro forma Form 1120 | Every year the LLC has a reportable transaction with its foreign owner, including money you put in or take out | IRS |
| BE-13 survey | Generally within 45 days when a foreign person sets up or buys a US business | BEA rule |
| State annual report or tax | Depends on the state; see US LLC annual fees by state | State filing office |
| Form 1040-NR | Only if the LLC has income effectively connected with a US trade or business | IRS |
The penalty for a missing or substantially incomplete Form 5472 is US$25,000, and it grows if the failure continues after an IRS notice (IRS).
What we need from an owner in Norway
To prepare the filing for an owner in Norway, we ask for:
- Your passport and your home address in Norway
- Your tax ID: For a resident of Norway, this is usually your national identity number, or a D-number if you were given one as a foreign national (OECD tax ID sheet).
- 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 Norwegian kroner where needed
The IRS wants all amounts in US dollars and the same tax ID used every year (IRS).
The US tax treaty with Norway and your LLC
Norway is on the IRS list of countries that have an income tax treaty with the United States (IRS treaty list). For an LLC owner, the treaty matters in two places.
Business profits and a permanent establishment
US treaties generally tax a treaty resident's business profits in the US only if they are attributable to a permanent establishment in the US, such as an office or a dependent agent. Taking that position on a US return is a treaty-based return position, disclosed on Form 8833; failing to disclose it carries a US$1,000 penalty (IRS Form 8833). Whether you qualify depends on the treaty's text, including any limitation on benefits article, so we read the actual treaty for your facts.
Treaty rates on Form W-8BEN
If a US payer pays you US-source income such as dividends, interest or royalties, the treaty claim on Form W-8BEN, naming Norway as your country of residence, is how you claim a lower withholding rate (IRS). Without a valid treaty claim, the general rate on that kind of income is 30% (IRS).
Reporting the LLC in Norway
Norwegian founders use a US LLC to sell software, services and products to US customers.
We do not advise on the tax law of Norway. Your local adviser decides how the LLC is reported at home, and we give them the US returns and numbers so both sides match.
Fees and next step
Owners in Norway 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 Norway.
Treaty
- The IRS lists the 1971 income tax treaty, amended by a 1980 protocol. General effective date (IRS Table 3): treaty Jan. 1, 1971; protocol Jan. 1, 1982 (IRS treaty documents for Norway; treaty text; IRS Table 3).
- Article 3 (Fiscal Residence), which decides who counts as a resident for treaty benefits.
- Article 4 (Permanent Establishment), which defines a US permanent establishment.
- Article 5 (Business Profits), under which business profits are taxed in the US only if attributable to a permanent establishment.
- Article 8 (Dividends), on dividends.
- Article 9 (Interest), on interest.
- Article 10 (Royalties), on royalties.
- Article 23 (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 Norway 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
- 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
- Bulgaria
- Cyprus
- Malta
Common questions
I live in Norway. When is my LLC's Form 5472 due?
With the pro forma Form 1120, normally by April 15 for a calendar-year LLC. Form 7004 extends it. The US$25,000 penalty applies if it is not filed.
Which tax ID from Norway do you need from me?
Your national identity number, or a D-number if you were given one as a foreign national. The IRS asks for the same foreign tax ID every year.
Does the United States have a tax treaty with Norway?
Yes. Norway 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.
Will I pay US income tax on my LLC's profit from Norway?
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)
- OECD: Information on tax identification numbers, Norway
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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