International Tax IssuesAnswered

Does the branch profits tax apply to a foreign-owned U.S. LLC treated as a disregarded entity?

CA
carlos_af35new member
May 27, 2021 1,678 views 1 answer
branch profits taxLLCdisregarded entityforeign individualIRC 884U.S. trade or business

I'm a non-U.S. individual operating a consulting business through a U.S. single-member LLC. I understand the LLC is a disregarded entity for tax purposes. Does the branch profits tax apply to me? I thought it only applied to foreign corporations, but someone told me the IRS could treat my LLC's activities as a U.S. branch of a foreign person. I'm confused about whether I need to worry about this.

Related Questions

InternationalAnsweredFeatured

I'm a foreign person owning a U.S. LLC — do I need to worry about GILTI?

I'm a non-U.S. resident who owns a single-member LLC in the United States. My LLC provides consulting services to clients in the U.S. and abroad. A friend told me about GILTI and said I should check i...

YB
yuki_b29c·Oct 25, 2020
2,1341
InternationalAnswered

What is the branch profits tax under IRC 884 and does it apply to my foreign corporation doing business in the U.S.?

I have a Japanese corporation that operates a trading office in Los Angeles. My U.S. tax advisor mentioned a 'branch profits tax' under IRC 884 that would apply on top of the regular corporate income ...

TJ
takeshi_jp_752d·Dec 14, 2024
9081
InternationalAnswered

What is the branch profits tax under IRC 884 and how does it apply to foreign corporations?

I'm a foreign corporation doing business in the U.S. through a branch (not a subsidiary). My U.S. tax advisor mentioned something called the 'branch profits tax' in addition to regular corporate incom...

H3
hans_3bc4·Jul 25, 2019
1,4561
InternationalAnswered

How does the India-U.S. DTAA apply to my disregarded LLC income?

I own a U.S. LLC that earns both consulting fees and some interest income from a U.S. bank account. I understand the India-U.S. DTAA should prevent double taxation, but I'm confused about how it works...

PI
priya_in_6ac4·Apr 7, 2019
1,6541
InternationalAnswered

Do interest limitation rules apply to a foreign-owned single-member LLC with intercompany loans?

My foreign company lent money to my U.S. LLC to fund operations. The LLC pays interest back to my foreign company. Does the Section 163(j) interest limitation apply to a disregarded entity LLC? If so,...

PB
pierre_b99a·Oct 15, 2023
1,0981
InternationalAnswered

My tax advisor mentioned IRC 269B 'stapled entities' — what does this mean and could it apply to my structure?

I'm an Israeli entrepreneur and I own both an Israeli company and a U.S. LLC. The ownership of both entities is identical — I own 100% of each. My tax advisor mentioned IRC 269B and said 'stapled enti...

EI
eli_il_ac4a·Dec 20, 2025
4121
InternationalAnsweredFeatured

What is the U.S. expatriation tax (exit tax) and who does it apply to?

I've been a U.S. green card holder for 12 years and I own a profitable LLC. I'm considering renouncing my green card and moving back to my home country permanently. A friend told me there's an 'exit t...

A4
anwar_46d7·Jan 31, 2021
2,9871
InternationalAnsweredFeatured

I'm from Australia — how does my U.S. LLC get taxed?

I'm an Australian citizen and tax resident in Sydney. I set up a Wyoming LLC for my SaaS business targeting U.S. customers. All development and operations happen from Australia. What are my U.S. and A...

LC
liam_c990·Apr 25, 2022
2,4561
InternationalAnswered

Does BEAT apply to my foreign-owned U.S. corporation that pays royalties to its parent?

I'm the tax director of a U.S. corporation wholly owned by a Japanese parent company. We pay substantial royalties and management fees to our parent — about $80 million per year. Our total deductions ...

T2
takeshi_20ec·Feb 17, 2022
1,2341
InternationalAnswered

My CPA said IRC 871 governs how I'm taxed as a nonresident alien — what does this section actually cover?

I'm a Japanese citizen running an online marketing agency through a U.S. LLC. I live in Tokyo and have never set foot in the U.S. My CPA said Section 871 of the IRC is the main section that determines...

YJ
yuki_jp_6c12·Nov 21, 2020
1,6541

Have a similar question?

ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.

Become a Member — $9.99/mo

Disclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.

Watch the walkthroughs