US LLC from Ireland: Revenue May See a Company of Its Own

0:00Can an Irish resident own a US LLC?

Orla builds software in Cork. She sells to customers in the United States, and some of their buyers want a US company on the contract. So, can she have one from Ireland? As far as America goes, yes. No social security number, and no trip to the US. Cheyenne, in Wyoming, is seven hours behind Ireland, all year round. We're BaseAcross. We set up US companies for founders outside America, so we'll be straight with you.

The American side is simple. The Irish questions are how Revenue sees the company, and where it's run from. Let's walk the fields, one wall at a time.

0:40Do I need a US company for Stripe in Ireland?

First field: does she need one at all? Here's what's different about Ireland. The big card processor already supports Irish businesses. An Irish limited company gets you it too, and it's what Irish banks and Revenue understand. So card payments aren't the reason. The reasons are selling as a US vendor, US contracts, US investors, or a platform that needs a US company. Orla has the first one.

1:10Does Revenue treat a US LLC as transparent?

Second field, and it's the one most videos skip. America usually disregards a one-owner LLC for tax. It looks straight through it, to you. Ireland may not. Revenue's own manual says a US LLC might, depending on the facts, be regarded as opaque. That means a company in its own right, not a pass-through. So don't assume the American view carries over. Your tax adviser decides it from the operating agreement, so take that to them.

1:43Can Ireland tax my US company as Irish?

Third field: where the company is run. A company managed and controlled in Ireland is Irish-resident, wherever it was formed. Here's the guide's own illustration. Say Orla's Wyoming LLC makes a hundred thousand euro of trading profit, and she makes its decisions from Cork. Then it's Irish-resident, and corporation tax takes twelve and a half thousand. Had that profit been interest, or other passive income, the higher rate would have taken twenty-five thousand.

What the company then pays her is a separate question, for her own return. That's an illustration, not a quote. Where the decisions are made, and how Revenue classes the LLC, decide the answer.

2:29Wyoming LLC or Delaware C-Corp, and the EIN

Forming it is the quick part. A Wyoming LLC for a business you run yourself, once you know how Revenue will treat it. A Delaware C-Corp if US investors want shares. Where its board meets and decides is the Irish question. The company needs a registered agent, an address in that state for legal papers, not where you work. Then the EIN. Without a social security number, it's a paper form to the IRS.

You'll pay in US dollars, so check your card's exchange rate and fees.

3:04Do I report a US bank account to Revenue?

The bank, and in Ireland this is the easy part. One of the US fintech banks takes applications from founders here, and a multi-currency account can give the company US account details. Each provider decides for itself, and can decline. But there's one Irish rule on banks. If you're resident and open an account outside Ireland in your own name, you usually become what Revenue calls a chargeable person.

You report the bank, the date it opened and the first deposit with your return. You're excused if the account is reported to Revenue automatically, and nothing else makes you a chargeable person. Ask your adviser.

3:45Is there a US–Ireland tax treaty?

Last, the American side. There's a US–Ireland income tax treaty in force. It takes US withholding off interest and royalties, and caps it on dividends. But pay for work you do in Ireland generally isn't US income, so for a services business the treaty matters less. And you're resident in Ireland for a year after a set number of days here, or a larger number over that year and the one before.

The company still files a report with the IRS every year, even without sales, and missing it is expensive. It's usually due in the spring, and there's a form to ask for more time, filed before the deadline.

4:26The order, and the checklist for your adviser

So here's the order. Take two questions to your adviser first: how Revenue will see the LLC, and where it will be managed. Then form, then bank. Keep minutes showing where the decisions are made. Put the IRS report and your Irish return on one calendar. The full guide, with every source and a checklist for your adviser, is linked below. And Orla? She took both questions to her adviser before she ordered anything.