Stateside Journal · Letter no. 56 · Banking

EIN for Foreign Owned LLC Without SSN: Phone, Fax or Mail

The IRS online EIN tool wants an SSN or ITIN and a US base. How the phone, fax and mail routes work for an LLC run from abroad, and what goes on line 7b.

The IRS says its online tool hands out an EIN in minutes and for free. For an owner living abroad, the same page lists conditions that close the door, so an EIN for foreign owned LLC without SSN has to come through a phone line, a fax machine or an envelope sent to Cincinnati.

I write from Lisbon, and for an owner here this is the step that comes right after the state approves the company. The IRS itself says the number works right away for opening a bank account or applying for business licenses, and it notes that companies can request one for banking purposes even when no federal tax rule demands it.

I do not see the paper route as a favour or a loophole.

It is the channel the IRS built for applicants outside the country, and its instructions say exactly what to write in the box where an American would put a Social Security number. Make sure the LLC is approved by the state before any of it starts.

Do not pay a website to do this for you either, because the IRS page for the online tool says it in one line: “You never have to pay a fee for an EIN.”

Why does the online EIN application turn away foreign owners?

The answer sits in a short checklist on the IRS page for the online tool, and a founder who runs the LLC from Europe or Latin America without an SSN or ITIN fails two of its four conditions at once. The business must have its principal place of business in the US or a US territory, and the applicant must hold a taxpayer number of a particular kind.

That second condition is phrased plainly on the page: “You have the responsible party’s Social Security number (SSN) or individual taxpayer ID number (ITIN).”

An EIN of another company does not count here. Only government entities may apply with one.

On the other side, the Form SS-4 instructions repeat the rule in their own words. An applicant with no legal residence, principal place of business, or principal office or agency in the United States or its territories cannot use the online application at all, they say, and has to pick one of the other methods.

I read that as a test of where the business is run, not where it was formed.

The online tool asks separately for a domestic organization and for a principal place of business in the US. For a founder in Bogotá running a one-person company, the residence, the principal place of business and the principal office all point abroad, even though the LLC itself is a Wyoming or Delaware company on paper.

Someone who runs the business from inside the US and holds an ITIN may meet the conditions after all. I would ask a tax adviser to confirm which side of the line a given company sits on, because the answer changes the channel.

A further limit applies on every channel, online or not, and it matters for anyone tempted to apply twice. The IRS allows one EIN per responsible party per day, whether the request comes online, by phone, by fax or by mail.

Do I need an ITIN before the IRS will give my LLC an EIN?

Not if the owner has no reason to hold one, and an ITIN requested only to get past the website adds a wait the IRS puts at seven weeks or longer from overseas. An ITIN serves federal tax purposes and nothing else.

On who needs one, the IRS page is direct: “You need an ITIN if you have a federal tax purpose and you’re not eligible for an SSN.”

A person with no US filing duty of their own may simply not qualify for an ITIN. The IRS adds a detail that matters here: “Generally, a tax return that contains all zero entries will not show a federal tax purpose.”

For that owner, the Form SS-4 instructions contain the sentence I would print and keep next to the form. Line 7b asks for the responsible party’s SSN, ITIN or EIN, and the instructions tell the applicant to write foreign or N/A there “if the responsible party doesn’t have and is ineligible to obtain an SSN or ITIN”.

They add that an entry is required, so the box should never be left blank.

On a quick look, the IRS page on responsible parties reads more strictly. It asks applicants to list the name and taxpayer ID number of the responsible party, and a founder reading only that page could conclude the whole application is impossible without an ITIN.

Both pages are official, and I trust the line 7b instruction because it is the one written for this exact case.

According to the same instructions, the responsible party has to be an individual, a natural person, unless the applicant is a government entity. A holding company abroad cannot stand in for its owner on line 7a, so the human being who controls the LLC goes there.

How does the IRS phone line for international applicants work?

The phone route is the fastest of the paper options, and the IRS reserves it for applicants outside the country. The number is 267-941-1099, and it is not toll free.

Staff answer on weekdays from six in the morning until eleven at night Eastern time, so from Lisbon or Madrid the window opens in the late morning and closes well after midnight.

Everyone else is shut out of the line by the instructions: “The IRS no longer issues EINs by telephone for domestic taxpayers.” A company with its principal place of business in a US state goes to the online tool, the fax or the mail instead.

Who calls matters as much as when the call happens. In the words of the instructions, “The person making the call must be authorized to receive the EIN and answer questions concerning Form SS-4.”

In practice that is the owner, or a third-party designee named on the form and authorized by the owner’s signature. The designee’s name, phone and fax go on the form.

A designee’s authority is temporary by design, the instructions explain. It ends at the moment the EIN is assigned and released, and the formal EIN notice is still mailed to the taxpayer.

I fill in the whole form before dialling, and I keep it next to the phone.

If the IRS representative asks for it, the instructions say to mail or fax the signed form, with any designee authorization, within a day to the address the representative gives.

How long do the fax and mail routes take?

Fax is the middle option, and the IRS publishes two different speeds for it. The instructions say the Fax-TIN program generally returns an EIN within four business days.

A second IRS page, on processing status for tax forms, gives another figure. It currently lists SS-4 faxes as “Processed 8 business days after receipt”, and I plan around the slower number of the two.

Applicants outside the country have a fax number of their own. The instructions direct anyone without a legal residence, principal place of business or office in a state or DC to fax 304-707-9471 when sending from outside the United States.

That line takes faxes around the clock, every day of the week. Fax-TIN numbers accept EIN applications and nothing else.

One sentence in the fax section saves a second attempt: “Be sure to provide your fax number so the IRS can fax the EIN back to you.” The return number on the form has to be one that can actually receive a fax, since the cover sheet with the EIN goes back to it.

Mail is the slow lane, and it needs a calendar more than a stamp. It takes about four weeks, by the IRS’s count.

Sending the form four to five weeks before the number is needed is the advice in the instructions. The status page adds that paper SS-4s are processed within 30 days of receipt, and neither page promises anything faster for envelopes posted abroad.

Foreign applicants have a separate mailing unit as well. They write to Internal Revenue Service, Attn: EIN International Operation, Cincinnati, OH 45999, and the instructions give a business line for asking about the status of a mailed application.

What should Form SS-4 international applicants write on the lines that matter?

Most of the form is ordinary, and a handful of lines decide whether it goes through without a letter asking for more. Line 1 takes the legal name exactly as it appears on the formation documents, and the IRS EIN page warns that its systems accept only letters, numbers, hyphens and ampersands in business names.

A foreign address needs every part spelled out.

The instructions ask for the city, the province or state, the postal code and the full name of the country, and they say not to abbreviate the country name, so Portugal stays Portugal on the form.

IRS systems allow 35 characters per street address. For a founder in Porto with a long street name, the EIN page points to the USPS standard abbreviations for fitting suite and apartment details into that space.

Lines 8a to 8c cover the LLC itself. They ask whether the applicant is an LLC, how many members it has, and whether it was organized in the United States.

Line 9a is where single-member owners slow down, because the instructions send a one-member LLC to the Other box. For an LLC wholly owned by a foreign person that requests the EIN for Form 5472 purposes, they say to tick Other and write “Foreign-owned U.S. disregarded entity-Form 5472” in the space provided.

A matching phrase goes under Other on line 10, the box that asks why the entity is applying.

Line 11 then wants the start date, and for foreign applicants the instructions define it as the date the business began or was acquired in the United States. Line 12 wants the closing month of the accounting year, and line 13 asks about employees, with zero as a valid answer.

Signature rules give foreign applicants more room: “Foreign applicants may have any duly authorized person (for example, division manager) sign Form SS-4.”

For a partnership or other unincorporated organization, the instructions name a responsible and duly authorized member or officer with knowledge of its affairs as the signer. The applicant’s telephone and fax numbers go beside the signature.

How do I get an EIN for foreign owned LLC without SSN on the first try?

I pick one channel and stay with it until the answer arrives. The instructions are blunt about mixing them: “Use only one method for each entity so you don’t receive more than one EIN for an entity.”

Example, invented to show the risk: a founder in Madrid faxes the form on a Monday, hears nothing by Friday and then calls the international line. If both requests go through, the LLC holds two numbers, and the IRS EIN page says a business entity should have only one.

An extra EIN cannot be cancelled by the IRS, only deactivated.

Forming the company with the state comes before anything else. The IRS page for the online tool warns that an EIN application may be delayed when the entity was not formed with the state first, and that sentence applies to every route.

Nominees are the second trap on this road. The IRS describes a nominee as someone given limited authority to act for the entity during its formation, and its page on responsible parties says a nominee cannot apply for the EIN or appear on Form SS-4.

If an agent handled the state filing, the real owner goes on line 7a, not the agent. Listing a nominee by mistake has to be corrected later on Form 8822-B, and the IRS warns the error could disclose the owner’s information to an unauthorized person.

The designee box on the form has its own catch. When the designee’s address or phone number matches the taxpayer’s, the instructions say the application must be mailed or faxed, so the phone release works only for a designee with separate contact details.

Once the number arrives, it works for banking at once. The IRS EIN page lists opening a bank account among the uses that need no wait, and for TIN matching, e-filing and electronic tax payments it asks for up to 2 weeks.

I keep every confirmation the IRS sends, on paper and as a scan.

Eligible users of the IRS Business Tax Account can download a digital notice, and the IRS says “The digital CP575 is accepted by banks and other institutions as written confirmation of an entity’s EIN.” The original paper notice cannot be duplicated or recreated.

What do the official pages leave out?

I have not found a published wait time for the international phone line. The hours are the only promise the IRS makes about it, and nothing on the pages says how long a caller from Lima or Lisbon sits on hold.

The two fax speeds stay unreconciled on the IRS site. Four business days in the instructions and eight on the status page may both be true at different moments, and I don’t know which one describes this month.

I cannot tell from the IRS pages whether a foreign owner with no SSN or ITIN can open a Business Tax Account at all.

The CP575 page speaks of eligible users and stops there, so the downloadable notice may be out of reach for exactly the people who applied by phone.

Nor have I seen any IRS figure for how many Form SS-4 requests come back with questions. The IRS does not speak for banks either: an EIN letter proves the company has a federal number, and whether a particular bank opens an account for an owner holding only a passport is that bank’s own policy.

Where does that leave a founder abroad?

A short note belongs here before anyone dials or faxes. A tax adviser who works with foreign owners, or the bank that will hold the account, can confirm the details of a given case.

That matters most for an LLC with two or more members or one that plans to elect corporate tax treatment on Form 8832.

My view at Stateside Journal on the EIN for foreign owned LLC without SSN is a simple one. For a single-member LLC run from outside the US, I think the phone line on a weekday is the shortest road and fax is the backup for anyone who cannot call during Eastern hours.

Mail fits only when nothing is waiting on the number. Fax stays open at night and on weekends.

The form itself is less frightening than its reputation, and line 7b has an answer written by the IRS for people like us. The Form SS-4 on the IRS site carries a December 2025 revision date, and I will keep checking those pages for changes to the phone hours, the fax numbers or the online tool’s rules.

With the EIN letter in hand, I would turn to the bank account next. A change of address or of the responsible party later goes on Form 8822-B within 60 days, and that deadline is easy to forget once the company is running.

Sources

  1. IRS, Employer identification number irs.gov.
  2. IRS, Get an employer identification number (online tool) irs.gov.
  3. IRS, Instructions for Form SS-4 irs.gov.
  4. IRS, Form SS-4 (Rev. December 2025) irs.gov.
  5. IRS, Responsible parties and nominees irs.gov.
  6. IRS, Processing status for tax forms irs.gov.
  7. IRS, Individual taxpayer identification number (ITIN) irs.gov.
  8. IRS, Understanding your CP575 notice irs.gov.