Form 5472 for Argentina Residents with a US LLC

An Argentina-resident owner of a US single-member LLC must file Form 5472 with a pro forma Form 1120 for every year the LLC had a reportable transaction with them. No US-Argentina income tax treaty appears on the IRS list of treaties in force, and the FTIN box takes your CUIT where ARCA has issued you one.

Argentina sends a steady stream of owners to Wyoming, Delaware and New Mexico LLCs: developers and agencies billing North American clients, ecommerce operators who need a US payment processor, and remote workers in Palermo or Villa Crespo. The LLC is there for one reason — a US bank account and a Stripe, PayPal or Wise balance clients can pay into.

Two features of the Argentine position change the mechanics compared with a UK or Indian owner: there is no treaty to fall back on, and which tax number you enter depends on which Argentine number you hold, because the country issues more than one. Neither removes the obligation.

If you would rather have this done than explained, we prepare and fax the complete package from $149.

Do Argentina residents have to file Form 5472?

Yes, on the same terms as every other non-US owner. Three conditions:

1. The LLC is a US disregarded entity — a single-member LLC that has not elected corporate treatment.
2. Its sole member is a non-US person: an Argentine citizen or resident who is not a US citizen, green card holder or US tax resident qualifies.
3. There was at least one reportable transaction during the tax year between the LLC and its owner or another foreign related party.

Under Treasury Regulation § 1.6038A-1, for tax years beginning on or after 1 January 2017 and ending on or after 13 December 2017, a foreign-owned US disregarded entity is treated as a corporation separate from its owner solely for the § 6038A reporting rules. Where you live and whether you pay Argentine tax are irrelevant to it.

Reportable transactions are money, property or services moving between you and your LLC. Customer revenue is not one.

The IRS Instructions for Form 5472 state that a $25,000 penalty may apply for failure to file when due and in the prescribed manner, for a substantially incomplete form, or for failure to keep required records — and that a substantially incomplete form is itself a failure to file.

Is there a US-Argentina tax treaty, and does it change anything?

Argentina does not appear on the IRS list of United States income tax treaties in force. Read by alphabetical section, the A entries run Armenia, Australia, Austria, Azerbaijan; Argentina is absent, and the absence is real rather than a search miss. Argentina is likewise absent from the US Treasury's table of tax treaties and related documents.

Keep the distinction competing content blurs: a treaty signed but never brought into force is not the same as no treaty relationship. What those lists establish is the fact that affects you — no US-Argentina income tax treaty is in force, so there is nothing to claim. Neither page documents an Argentine treaty awaiting ratification, and we assert nothing either way about one.

That absence has two effects and one non-effect. There is no permanent establishment article to rely on, so whether your income is effectively connected with a US trade or business is decided under US domestic law alone — usually no, for a business run from Argentina with no US office or staff, though US-held inventory deserves a professional opinion. There is no treaty-reduced withholding on US-source passive income. And nothing changes about Form 5472, an information return under § 6038A that no treaty exempts anyone from.

What goes in the FTIN box — CUIT, CUIL or neither?

Enter the Argentine tax number you actually hold. Argentina's tax identification key is the CUIT, the clave única de identificación tributaria, administered by ARCA, the agency that replaced AFIP. A different number, the CUIL — código único de identificación laboral — comes through ANSES: the government's own page describes it as the code needed at the start of an employment relationship and for claiming ANSES benefits.

Foreigners resident in Argentina without a DNI are not shut out of the tax register. ARCA's page for foreign residents without a DNI describes a provisional CUIT valid for a maximum of two years, or until the residency authorisation expires, issued on a passport or home-country identity document, form 460 F/PD and a Migraciones certificate showing the character of your residency.

Part II asks for the owner's identifying numbers. The US requirement does not move from row to row:

Two cautions on the fifth row. Whether ARCA treats a CUIL as a tax identification key for someone who never registered as a taxpayer is not something we can confirm from an official page, so treat it as unverified and ask an Argentine accountant. And never enter a DNI: an identity document is not a tax identification number.

Line 4b(1) is for a US identifying number, which most Argentine owners leave blank. Where it is blank, a self-assigned reference ID on line 4b(2) is required — the identical string every year, as our FTIN and reference ID guide explains. Do not apply for a US ITIN merely to fill the box. For the Part II address, use your real Argentine address, not the LLC's registered agent.

Does Argentine tax residency affect the US filing?

No. It affects what you may owe in Argentina, a separate question for a separate authority — but the test is worth knowing, because Argentina's is not the 183-day rule nomads trade in coworking spaces.

ARCA's guidance on residencia for income tax treats Argentine nationals as residents, subject to exceptions for those who take permanent residence abroad or stay continuously outside the country for twelve months, and treats foreign nationals as residents where they have obtained permanent residence in Argentina or, without obtaining it, have remained on temporary authorisations for a period of twelve months. A six-month test appears there only for personal deductions; no 183-day residency test for foreign nationals appears at all.

Argentina does offer a nomad route. The official page for transitory residence as a digital nomad cites article 24(h) of Law 25.871, Decree 616/2010 and DNM Disposition 758/2022, is open to nationals of countries that do not need a tourist visa, and grants up to 180 days, renewable for an equal period, to people providing remote services to clients abroad. Whether your own pattern of stays crosses ARCA's twelve-month line is a question for an Argentine adviser; either way, Argentine residency neither creates nor removes a US filing obligation. If this year is Buenos Aires and next year Montevideo, our guide for nomads with no fixed tax residence covers the pattern.

How do you convert peso amounts for Form 5472?

The form is completed in US dollars, and this post deliberately quotes no peso rate: published rates move, and a rate copied out of a blog post is not support for a filing. Use a rate you can name, applied consistently, with the source written into your workpapers — our currency conversion guide sets out the options. Most LLC movements are in dollars anyway, because the LLC banks in dollars.

We make no claim here about Argentine foreign-exchange rules or what rate is available for any transaction; ask ARCA, the Banco Central or an Argentine adviser. Form 5472 asks something narrower: dollar amounts, on a stated basis.

How does an Argentina-based owner actually file?

You cannot e-file. The IRS instructions state that a foreign-owned US DE cannot file Form 5472 electronically, and no consumer tax software supports it.

1. Prepare the pro forma Form 1120 with "Foreign-owned U.S. DE" across the top of page 1. Only the LLC's name and address and items B and E are required.
2. Prepare Form 5472 — Part I for the LLC, Part II for you with your Argentine address and CUIT or reference ID, Part III for the related party, Part IV for listed monetary transactions, and Part V with an attached statement itemising contributions, distributions and loans.
3. Convert every non-dollar amount at a named published rate, and state the basis in Part V.
4. Sign, then fax to 855-887-7737, or mail to Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201.
5. Keep the timestamped transmission receipt. The IRS sends no acknowledgement, and that receipt is evidence of transmission, not acceptance.

The regular due date for a calendar-year LLC is generally 15 April, extended by a timely Form 7004 under the special disregarded-entity instructions — see our deadline guide.

Getting it filed from Argentina

The Argentine specifics — no treaty, a CUIT or a reference ID rather than a guess, a second related party when an Argentine company sits alongside the LLC — are routine once seen, and are what makes a self-prepared package come back incomplete.

Form5472 Prep prepares the whole package: Form 5472 with the identifying numbers handled correctly, the pro forma Form 1120, and the Part V statement. A qualified tax accountant reviews each one before we fax it to the IRS Ogden PIN Unit and return the timestamped confirmation. Late years include a reasonable cause cover letter.

$149 Standard, ready in 5 to 7 business days. $199 Express, within 3 business days. +$99 per additional past year. IRS fax delivery included — see pricing.

We are not a CPA firm and we do not give tax advice, and we do not advise on Argentine tax or currency rules. We prepare and submit the US information return accurately.

Start your filing — about 15 minutes.

Frequently asked questions

Do I have to file if I live in Buenos Aires and my clients are all outside the US?

Yes. Form 5472 is an information return, not a tax return, and does not depend on where clients are or on owing US tax. If money moved between you and your LLC, it is required.

Is there a tax treaty between the United States and Argentina?

No income tax treaty with Argentina appears on the IRS list of treaties in force or in the Treasury treaty table. There is nothing to claim: no permanent establishment article, no reduced withholding.

Which number goes in the FTIN box, my CUIT or my CUIL?

The CUIT is Argentina's tax identification key and is the natural entry where ARCA has issued you one. If a CUIL is your only number, ask ARCA or an Argentine accountant which identifies you.

I am on the digital-nomad transitory residence. Does that change the filing?

No. That is an immigration status. The filing turns on the LLC being a foreign-owned US disregarded entity that had a reportable transaction with you during the year.

Do I report peso amounts or US dollars?

US dollars. Convert at a published rate you can name, applied consistently, and record the source and date in your workpapers and Part V statement. Keep the statements showing peso figures.

I have never filed and the LLC is two years old. What now?

File the outstanding years as soon as you can with a reasonable cause statement, before the IRS contacts you. See filing late or never having filed.

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No treaty, a tax number that depends on which register you are in, a currency worth documenting: Argentina changes how the package is assembled, not whether it is due.

Start your Argentina filing, or read the FTIN and reference ID guide first.

Educational content only; not tax or legal advice.