Form 5472 for Taiwan Residents with a US LLC
Taiwan is not on the IRS treaty list, and double-tax relief legislation is unconfirmed. See what that changes for Form 5472 and what goes in the FTIN box.
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Last updated September 20, 2026
A Taiwan-based owner of a US single-member LLC must file Form 5472 with a pro forma Form 1120 each year the LLC had a reportable transaction with them. Taiwan is not on the IRS treaty list, and the owner's Taiwanese Taxpayer ID No. — the ID card or ARC number — goes in the FTIN box.
Taiwan sends a steady stream of owners to Wyoming, Delaware and New Mexico LLCs: cross-border ecommerce sellers shipping out of Taichung, hardware consultants invoicing US clients, SaaS founders who need US banking, and Employment Gold Card holders running a remote practice from Taipei.
Two features of the Taiwan position change the mechanics of the filing compared with a UK or Indian owner: there is no comprehensive US–Taiwan income tax treaty on the IRS list, and the personal tax number you will be asked for is issued by an immigration authority rather than a tax authority. Neither removes the obligation.
If you would rather have the filing done than explained, we prepare and fax the complete package from $149.
Do Taiwan residents have to file Form 5472?
Yes, on exactly the same terms as an owner in a treaty country. Three conditions have to be present:
- The business is a US disregarded entity — a single-member LLC that has not elected corporate treatment.
- Its sole member is a non-US person. A Taiwan resident who is not a US citizen, green card holder or US tax resident qualifies.
- The LLC had at least one reportable transaction with its owner or another foreign related party during the tax year.
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. That is what puts an ordinary Taipei-run LLC inside a corporate information-reporting regime.
Reportable transactions are money, property or services moving between you and your own LLC: capital contributions in, distributions out, loans in either direction, and payments for goods or services. Customer revenue is not a reportable transaction. A Stripe or Wise payout collected from your customers does not go on the form. A transfer out of that balance into your personal NT dollar account at CTBC or Cathay United does.
For a typical Taiwan-based owner:
- NT dollars converted and wired to open the LLC's Mercury or Relay account — reportable capital contribution
- Every transfer taken back out to yourself since — reportable distributions
- Cash you lent the LLC to cover ad spend — reportable loan
- Amounts the LLC paid to a Taiwanese company you also own — reportable, and that company is a second related party with its own Form 5472
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 5472, or for failure to maintain the required records. A substantially incomplete form counts as a failure to file. Where the failure continues more than 90 days after the IRS mails its notice, a further $25,000 applies for each 30-day period, or fraction of one, after that window, per related party.
Does a US–Taiwan tax treaty change anything?
Taiwan is not on the IRS list of income tax treaties in force. Reading the IRS treaty A-to-Z page by alphabetical section, the T entries are Tajikistan, Thailand, Trinidad, Tunisia, Turkey and Turkmenistan. Taiwan appears nowhere on the page.
Two separate things have been in motion, and no official US source we could fetch describes either as settled law:
- A comprehensive agreement. The US Treasury announced on 29 October 2024 that the United States and Taiwan, under the auspices of the American Institute in Taiwan and the Taipei Economic and Cultural Representative Office, would begin negotiating a comprehensive agreement to address double taxation. That is negotiations starting, not an agreement in effect.
- Legislation. Title I of H.R. 33 in the 119th Congress is the "United States-Taiwan Expedited Double-Tax Relief Act", which would insert a new section 894A, "Special rules for qualified residents of Taiwan", into the Internal Revenue Code. The Government Publishing Office's text of the bill as received in the Senate on 16 January 2025 records it being read twice and referred to the Committee on Finance.
As at 20 September 2026 we could not confirm from any official US source — the IRS, the Treasury or the published US Code — that US–Taiwan double-tax relief has taken effect. Treat that position as unverified. There is no Taiwan entry on the A-to-Z list and no Taiwan page in the IRS treaty documents series. If relief matters to you, confirm the current status with the IRS or a qualified US tax adviser rather than with news coverage or a firm's newsletter.
The reporting side, by contrast, is not in doubt:
| Question | Changed by the absence of a treaty? | Position for a Taiwan-resident owner |
|---|---|---|
| Does the LLC file Form 5472? | No | Required for every year with a reportable transaction, identically to a treaty-country owner |
| Does it attach to a pro forma Form 1120? | No | Yes — with "Foreign-owned U.S. DE" written across the top of page 1 |
| Can it be e-filed? | No | No. Fax to 855-887-7737 or mail to the Ogden PIN Unit |
| Does the $25,000 penalty exposure apply? | No | Yes, per form, per year, with continuation amounts after an IRS notice |
| Is a reduced withholding rate available on US-source dividends, interest or royalties? | Yes | No treaty rate to claim; the statutory rules apply |
| Is there a permanent establishment article to rely on? | Yes | None. Whether income is effectively connected with a US trade or business is decided under US domestic law alone |
| Can a treaty-based return position be taken? | Yes | No treaty, so no treaty-based position and no treaty-claim disclosure |
Treaties allocate taxing rights over income. Form 5472 is an information return under IRC § 6038A. No treaty exempts anyone from filing it, so the absence of one takes nothing away either.
What goes in the FTIN box for a Taiwan-resident owner?
Enter the owner's Taiwanese Taxpayer ID No. as the foreign taxpayer identifying number, and add a self-assigned reference ID whenever there is no US identifying number to report.
The National Taxation Bureau of Taipei explains that the Taxpayer ID No. is issued by the National Immigration Agency and appears on the Alien Resident Certificate for foreign taxpayers residing in Taiwan, or on a Record of ID No. in the Republic of China for Hong Kong, Macau and PRC nationals and overseas Chinese. The format changed on 2 January 2021 from two letters plus eight digits to one letter plus nine digits, with a transition period to 31 December 2030, so an older number may look different from a recently issued one. A Taiwanese national uses the ID card number.
| Part II line | Entry for a Taiwan individual owner | Handling |
|---|---|---|
| 4b(1) | A US identifying number only if the owner already has one | Most Taiwan-resident owners leave this blank; never borrow or invent a US number |
| 4b(2) | Self-assigned alphanumeric reference ID | Required when 4b(1) is blank; reuse the identical ID every year |
| 4b(3) | The Taiwanese Taxpayer ID No. — ID card number, or the number on the ARC or Gold Card | If the owner genuinely holds no foreign tax number anywhere, enter "None" or "N/A" rather than leaving it blank |
| 4a | The owner's name and actual Taiwan address | Never the LLC's US registered-agent address |
Two mistakes recur: entering the LLC's EIN in the owner's FTIN field, when the EIN belongs to the entity in Part I; and applying for a US ITIN purely to fill this box, when the reference ID mechanism exists so that a foreign owner can file without one. Our FTIN and reference ID guide covers the blank-box problem, including the owner who has left Taiwan and holds no current tax number anywhere.
Does Taiwan tax affect the US filing?
No. Taiwanese personal income tax and the US information return are separate systems, and nothing you do in one satisfies the other.
In outline, and only as context: the Ministry of Finance states that an individual who stays in the Republic of China for 183 days or more within a taxable year is regarded as a resident, assessed at progressive rates on net consolidated income, which the Ministry describes as including income derived within the R.O.C. and remuneration derived outside the R.O.C. for service rendered in the R.O.C. Below that threshold it describes two treatments — under 90 days, and 90 days up to 183 days — both driven by withholding. Separately, the National Taxation Bureau of Taipei gives the annual filing period as 1 to 31 May.
The Employment Gold Card is issued under the National Development Council's programme and combines a visa, residency, open work authorisation and a re-entry permit in one card, valid for up to three years. The Gold Card Office's pages refer to tax benefits for qualifying foreign special professionals; we have not verified the eligibility conditions or amounts, so treat that as unverified and check it with the National Taxation Bureau.
How Taiwan treats the profits of a US LLC you own is a question for that Bureau or a local adviser, and we do not advise on it. What is certain from the US side is that holding a Taxpayer ID No., filing a Taiwanese return, or holding a Gold Card neither creates nor removes the Form 5472 obligation.
How does a Taiwan-based owner actually file?
You cannot e-file. A foreign-owned US disregarded entity has to send the package on paper, and no consumer tax software supports it.
- Separate the ledger. Split customer receipts and third-party costs away from contributions, distributions, loans and owner-paid expenses.
- Prepare the pro forma Form 1120 — the LLC's name, EIN, address, and items B and E — with "Foreign-owned U.S. DE" written across the top of page 1.
- Prepare Form 5472 — Part I for the LLC, Part II for you with your Taiwan address and Taxpayer ID No., Part III for the related party, Part IV for the monetary transaction categories, and Part V with an attached statement itemising contributions and distributions.
- Convert NT dollars to US dollars at a reasonable rate for each transaction date, applied consistently, and state the basis in the Part V statement.
- Fax to 855-887-7737, or mail to Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201.
- Keep the timestamped transmission receipt. The IRS sends no acknowledgement, and the receipt is transmission evidence rather than IRS acceptance of the return.
An illustrative workpaper, not a rate claim. Assume the owner's own records show NT$32.00 to the US dollar on each transaction date:
| Illustrative transaction | NTD amount | Arithmetic | USD amount |
|---|---|---|---|
| Owner capital contribution | NT$320,000 | 320,000 ÷ 32.00 | USD 10,000 |
| Distribution to owner | NT$96,000 | 96,000 ÷ 32.00 | USD 3,000 |
| Owner-paid software bill | NT$6,400 | 6,400 ÷ 32.00 | USD 200 |
| Gross related-party value reviewed | 10,000 + 3,000 + 200 | USD 13,200 |
For a 2025 calendar-year LLC the package was due 15 April 2026, extended to 15 October 2026 by a Form 7004 sent to the same PIN Unit by the regular due date. Our deadline guide sets out the calendar.
Getting it filed from Taiwan
The Taiwan specifics — no treaty on the IRS list, a Taxpayer ID No. issued by an immigration authority, NT dollar conversion, and often a Taiwanese company as a second related party — are routine once handled before, and they are exactly what makes a self-prepared package come back as substantially incomplete.
Form5472 Prep prepares the complete package: Form 5472 with the FTIN and reference ID handled correctly, the pro forma Form 1120, and the Part V supporting statement. A qualified tax accountant reviews it, we fax it to the IRS Ogden PIN Unit, and we return the timestamped confirmation receipt. Late years include a reasonable cause cover letter.
$149 standard, ready in 5–7 business days. $199 express, within 3 business days. +$99 per additional past tax year. IRS fax delivery is included, so you never send an international fax from Taipei.
We are not a CPA firm and we do not give tax advice. Taiwanese income tax, Gold Card tax questions, US income-tax exposure and the status of any future US–Taiwan relief need the appropriate adviser; we prepare and submit the US information return.
Start your filing — about 15 minutes.
Frequently asked questions
Does a Taiwan resident need to file Form 5472?
Yes, when a foreign-owned US single-member LLC had a reportable transaction with its owner or another related party during the year. Contributions, distributions, loans and owner-paid costs commonly trigger it even when the LLC made no sales.
Is there a US–Taiwan tax treaty?
Taiwan does not appear on the IRS list of income tax treaties in force. Treasury announced negotiations toward a comprehensive agreement in October 2024. We could not confirm from an official US source that any relief has taken effect, so treat that as unverified and check with the IRS.
Has the United States-Taiwan Expedited Double-Tax Relief Act become law?
We cannot confirm that it has. The Government Publishing Office records H.R. 33 being received in the Senate and referred to the Committee on Finance on 16 January 2025. Confirm the current status with the IRS or an adviser rather than relying on commentary.
What FTIN do I use as a Taiwan-resident owner?
Use your Taiwanese Taxpayer ID No. — the ID card number, or the number shown on your Alien Resident Certificate or Gold Card. If you truly hold no foreign tax number, enter "None" or "N/A" instead of leaving the box empty.
Does holding an Employment Gold Card change the US filing?
No. The Gold Card is a Taiwanese visa, residence and work authorisation. It does not alter whether a US LLC is a disregarded entity, whether its owner is a foreign person, or whether Form 5472 is due.
Are my Shopify or Stripe sales reported on Form 5472?
No. Customer revenue is not a reportable transaction. What is reportable is the money moving between you and your LLC — funding in, withdrawals out, loans, and bills you paid personally on the LLC's behalf.
I have never filed and my LLC is three years old. What now?
File the outstanding years as soon as you can, with a reasonable cause statement based on the actual facts, before the IRS makes contact. Each year carries its own exposure. See our late filing guide.
No treaty on the IRS list means no treaty relief to claim — not a lighter filing. If money moved between you and your US LLC this year, Form 5472 and the pro forma 1120 are due.
File from Taiwan in about 15 minutes, or read how to fill out Form 5472 first.
Splitting the year across several countries? The Form 5472 guide for digital nomads covers filing when you have no single tax residence.
Educational content only; not tax or legal advice.