δΈΊδΈε½εε§δΊΊζδΎη Form 5472 εθ§ζε
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Many Chinese founders incorporate via Stripe Atlas or doola for U.S. payment rails. Here's the Form 5472 + pro forma 1120 playbook, including the U.S.-China treaty essentials, banking realities, and the OBBBA 2026 remittance tax.
You file. We never touch your IRS submission. Read in δΈζ β
The U.S.-China Income Tax Treaty (1984) reduces certain withholding rates and provides residency tie-breaker rules. It does NOT eliminate Form 5472. Note: this treaty applies to mainland China only β Hong Kong and Macau are separately treated (HK has its own arrangement; Macau has none).
| Payment type | Withholding | Note |
|---|---|---|
| Dividends to Chinese resident | 10% | Article 9 β reduced from 30% statutory. |
| Interest to Chinese-resident lender | 10% | Article 10. |
| Royalties | 10% | Article 11. |
| Permanent establishment threshold | β | Article 5 β important for ECI determinations. |
Read the full treaty on IRS.gov: China tax treaty documents.
Withholding-rate planning is separate from Form 5472. Form 5472 is an information return on the LLC; withholding is on payments from U.S. payors. Both can apply.
18-character resident ID number for individuals (matches your θΊ«δ»½θ―ε·η ); 18-character Unified Social Credit Code for entities.
For Form 5472 line 1c, use your 18-character resident ID for individual owners or your entity's USCC. The IRS does not validate format.
Chinese mainland-resident founders face the most banking friction. Mercury and Relay rarely approve mainland residents without a U.S. base or U.S. ties. Wise is the typical realistic path, with HSBC also an option.
Most realistic for mainland-resident founders. EMI, not a bank.
Generally declines mainland-Chinese residents without U.S. ties; HK-based applicants fare better.
Rarely approves mainland-Chinese-resident founders.
Possible if you already have an HSBC banking relationship in mainland China or Hong Kong.
We do not have a paid partnership with any U.S. business banking provider listed here; status reflects approval patterns reported by founders we've interacted with, current as of May 2026. Verify before relying.
Selling to U.S. customers via Amazon / Shopify from a U.S. LLC, sourcing from mainland Chinese suppliers.
What you do: Form 5472 + likely large reportable transactions (supplier purchases from related parties if any). Use /filer.
Stripe billing through U.S. LLC; funds opex from China.
What you do: Form 5472 required. Watch ECI threshold if you maintain U.S. presence.
Revenue from U.S. platforms (YouTube, Substack, AdSense) routed through U.S. LLC.
What you do: Form 5472 required. Treaty reduces withholding on certain payments; W-8BEN required.
The Form 5472 wizard takes about 15 minutes. You sign and submit yourself.