As a perpetual traveler with a single member US LLC (disregarded entity), I have some questions about the CTA /beneficial owner reporting in 2024. I understand that CTA requires a physical US address for the LLC, rather than just a registered office address? Is a physical US office address needed for the LLC, or can the LLC owner declare an address abroad where the business is conducted ? If the address needs to be in the US, what services exist to rent a CTA compatible address and by what date this needs to be set up? If one has a physical US address for the LLC, could this create an ETBUS link /tax liability in the US (even if the owner is non-US citizen, non-US resident, with no operations in the US)? When reporting the address of the US LLC beneficial owner, is an address proof required? What would be an acceptable address if the owner has no personal tax residence/no permanent establishment? Thank you in advance.
CTA - US LLC physical address
- Thread starter artmiriam30
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You should simply make a photoshop utility bill or get one, it's easy to find people that can do it.
Which address abroad? As a perpetual traveler I have dozens of short term accommodations per year and I don't keep a long term residencial property. If I declare a previous residential address for which I still have bank accounts, couldn't this trigger tax liability in the previous country of tax residence (Portugal in this case).
it must be a US adress: "
"Complete current U.S. address:
» Report the address of the principal place of business in United States, or, if the reporting
company’s principal place of business is not in the United States, the primary location in
the United States where the company conducts business."!!!
"Complete current U.S. address:
» Report the address of the principal place of business in United States, or, if the reporting
company’s principal place of business is not in the United States, the primary location in
the United States where the company conducts business."!!!
Your own residential address can be abroad, but your US LLC address must be in the US. I do not see any requirement in the beneficial owner reporting that the US LLC address must be a so called "physical address" though, nor any requirement for address proof.
You can't put your registered agent address as your US LLC address, but you can put any address where you can receive mail, and one usually gets such an address when one sets up a US LLC, and having such an address doesn't cause one to be Engaged in Trade or Business in the US (ETBUS).
Note that︀ the beneficial owner reporting is with Fincen not the IRS. The purpose of it is︁ to combat money laundering and terror financing and stuff like that, and they want to︂ know the individual owner behind complex corporate structures. It doesn't impact taxation.
I'm half starting︃ to think that this talk about physical address requirement causing ETBUS is scare tactics spread︄ by people trying to sell company set ups in other jurisdictions. It hurts their business︅ if people go with the much cheaper US LLC option. I just haven't seen any︆ solid well sourced information about this requirement, and Im not sure "physical address" is even︇ a legal term.
American accountant James Baker covers the address part at the 4 min︈ mark here:
You can't put your registered agent address as your US LLC address, but you can put any address where you can receive mail, and one usually gets such an address when one sets up a US LLC, and having such an address doesn't cause one to be Engaged in Trade or Business in the US (ETBUS).
Note that︀ the beneficial owner reporting is with Fincen not the IRS. The purpose of it is︁ to combat money laundering and terror financing and stuff like that, and they want to︂ know the individual owner behind complex corporate structures. It doesn't impact taxation.
I'm half starting︃ to think that this talk about physical address requirement causing ETBUS is scare tactics spread︄ by people trying to sell company set ups in other jurisdictions. It hurts their business︅ if people go with the much cheaper US LLC option. I just haven't seen any︆ solid well sourced information about this requirement, and Im not sure "physical address" is even︇ a legal term.
American accountant James Baker covers the address part at the 4 min︈ mark here:
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