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Reviewed By Abdul Mannan, CA & California-Licensed CPA
Last reviewed: September 2026
Yes, you can generally get an EIN for a U.S. LLC without an SSN. A non-U.S. resident may also be able to obtain an EIN without an ITIN. If the responsible party does not have and is ineligible to obtain an SSN or ITIN, the IRS allows “foreign” or “N/A” to be entered on Form SS-4, Line 7b.
The process is different from the standard online EIN application for many non-U.S. applicants. If your legal residence, principal place of business, or principal office or agency is outside the United States or U.S. territories, you cannot use the IRS online EIN application. Instead, international applicants can apply by phone, fax or mail.
This blog explains how to get an EIN for the U.S. LLC without an SSN, what to enter on Form SS-4, how Line 7b works, which application method to use, and what to review after receiving the EIN. If you are still setting up your U.S. business, you can see our guide on how to form a U.S. LLC from Pakistan.
Yes. An SSN is not automatically required for a foreign responsible party to obtain an EIN.
The key issue is how the responsible party completes Form SS-4. The IRS requires the responsible party’s name on Line 7a and an SSN, ITIN, or EIN on Line 7b. However, when the responsible party does not have and is ineligible to obtain an SSN or ITIN, the current IRS instructions specifically allow “foreign” or “N/A” on Line 7b. This is particularly relevant to founders who live outside the United States and own a U.S. LLC.
It is not necessarily. An ITIN is not a universal prerequisite for obtaining an EIN. The IRS’s current Form SS-4 instructions specifically provide a procedure for a responsible party who has neither an SSN nor ITIN and is ineligible to obtain one.
However, do not treat “foreign” or “N/A” as a universal replacement for an SSN or ITIN. The IRS also has special instructions for certain foreign entities applying for an EIN for tax-treaty or withholding purposes. Your entry should therefore reflect why the EIN is being requested and the responsible party’s actual circumstances.
Not necessarily. Whether a U.S. LLC needs an EIN depends on its ownership structure, federal tax classification, and specific tax or reporting obligations.
For example, a single-member LLC treated as a disregarded entity can have different federal tax requirements from a multi-member LLC or an LLC taxed as a corporation. The IRS recognizes partnerships, corporations, and disregarded entities as possible federal tax classifications for LLCs.
An EIN may be required for purposes such as:
Important exception for foreign-owned LLCs: A foreign-owned U.S. single-member LLC treated as a disregarded entity must obtain an EIN when it is required to file Form 5472. This EIN requirement applies specifically to the Form 5472 filing and can apply even when the LLC has no employees or other U.S. business activity.
The IRS also allows a business to request an EIN for banking or state tax purposes even when it does not otherwise need one for federal tax purposes.
The key distinction is that forming an LLC and determining whether it needs an EIN are separate questions. However, specific federal reporting requirements, such as Form 5472 for certain foreign-owned U.S. disregarded entities, can create an EIN requirement.
Prepare the information for the LLC and its responsible party before starting Form SS-4.
You may need:
If the LLC has not yet been formed, complete the state formation process first when required. For Pakistani founders establishing a U.S. business, the EIN should be viewed as one part of the wider entity, tax and compliance setup rather than as the entire process.
The responsible party is the individual who ultimately owns or controls the entity or exercises ultimate effective control over it. For most businesses, the IRS requires the responsible party to be an individual rather than another company or entity.
For a foreign-owned U.S. LLC, this will often be the individual owner who actually controls the business.
Not simply because the registered agent receives legal documents for the LLC. A registered agent should not automatically be listed as the responsible party. The person listed on Form SS-4 should meet the IRS definition of responsible party and have the required level of ownership or control.
A third party can assist with the application when properly authorized, but assistance with Form SS-4 does not make that person the LLC’s responsible party. The individual who actually owns or controls the entity should be identified correctly.
Form SS-4 is the IRS application for an EIN. The current version is available directly from the IRS Form SS-4 page.
For a foreign-owned U.S. LLC, several lines deserve particular attention.
Enter the LLC’s legal name exactly as it appears on its formation documents.
Do not substitute a brand name, shortened name, or nickname for the legal entity name.
The IRS requires an entry on Line 1.
Enter the mailing address where the IRS can send correspondence. If the mailing address is outside the United States, enter the city, province or state, postal code, and country. Do not abbreviate the country name.
Enter the full name of the individual who ultimately owns or controls the LLC or exercises ultimate effective control over it.
A registered agent may still be required for the LLC under state law, but they should not automatically be listed as the IRS responsible party simply because they serve as the registered agent. The same applies to an accountant, formation service, or another third party that helped establish the company.
This is the most important line for many non-U.S. founders. If the responsible party does not have and is ineligible to obtain an SSN or ITIN, the current IRS instructions say to enter:
“foreign” or “N/A”
on Line 7b. An entry is required. Do not enter a fabricated SSN, another person’s taxpayer identification number, or an unrelated EIN.
Also, do not assume that every foreign applicant should automatically enter “foreign.” The IRS provides separate instructions for certain foreign entities applying for an EIN for tax-treaty purposes.
If the application is for an LLC, answer the LLC questions about:
The answers help determine how the EIN application is processed and what entity information applies.
Line 9a asks for the type of entity applying for the EIN.
For an LLC, the correct entry depends on its structure and circumstances. The IRS specifically notes that Line 9a is not itself an election of federal tax classification.
For example, the current instructions explain different treatment for disregarded entities, partnerships, and corporations. If a single-member U.S. LLC is requesting an EIN specifically for Form 5472 purposes, the IRS instructions provide a specific Line 9a entry for a foreign-owned U.S. disregarded entity.
Choose the reason that actually applies to the EIN request. The IRS requires a selection on Line 10; “N/A” should not simply be used because the applicant is a foreign founder.
Not if you are an international applicant who does not meet the IRS online eligibility requirements.
The IRS states that applicants without a legal residence, principal place of business, or principal office or agency in the United States or U.S. territories cannot use the online EIN application. This is an important distinction for founders living in Pakistan.
Your LLC may be formed in Delaware, Wyoming, New Mexico, or another U.S. state, but that does not automatically mean you qualify for the online EIN application.
If your relevant business location is outside the United States, use one of the international application methods below.
International applicants who cannot use the online application can apply by phone, fax, or mail.
International applicants can call the IRS at: 267-941-1099
The current IRS instructions list the international telephone service as available Monday through Friday, 6:00 a.m. to 11:00 p.m. Eastern Time. The number is not toll-free. Complete Form SS-4 before calling so you have the required information available.
If you are outside the United States, the current IRS instructions list: 304-707-9471 for international applicants.
Under the IRS Fax-TIN program, an EIN is generally returned by fax within 4 business days when the application is complete and a fax number is provided.
International applicants can mail Form SS-4 to:
Internal Revenue Service
Attn: EIN International Operation
Cincinnati, OH 45999
The IRS recommends submitting the application approximately 4 to 5 weeks before the EIN is needed and states that the EIN will arrive by mail in approximately four weeks. Always verify the current mailing address and instructions before sending the form.
| Method | International applicant | Typical IRS timing | Best for |
|---|---|---|---|
| Online | Not when the applicant does not meet online eligibility | Immediate when eligible | Applicants who qualify for the online system |
| Phone | Yes | During IRS processing | Applicants who can speak directly with the IRS |
| Fax | Yes | Generally within 4 business days | Applicants who want a faster non-online option |
| Yes | Approximately 4 weeks | Applicants who prefer postal filing |
The IRS also states that a responsible party generally should not apply for more than one EIN per day. For many founders outside the U.S., fax is a practical route when they do not qualify for the online system and want to avoid the longer mail timeline.
Being the registered agent does not, by itself, make someone the IRS responsible party.
Never use an invented number or someone else’s taxpayer identification number. If the responsible party does not have and is ineligible to obtain an SSN or ITIN, follow the current IRS instruction for Line 7b.
The “foreign” or “N/A” instruction applies to a responsible party who does not have and is ineligible to obtain an SSN or ITIN. Certain foreign entities applying for an EIN for treaty or withholding purposes have additional instructions.
A U.S.-formed LLC does not automatically make its foreign owner eligible for the online EIN application. Check the applicant’s actual residence and principal business location against the IRS requirements.
LLC ownership and federal tax treatment affect how Form SS-4 should be completed. Do not select an entity type simply because “LLC” appears to be the obvious answer. Review the applicable IRS instructions for the LLC’s structure.
Do not repeatedly submit Form SS-4 simply because you are waiting for the EIN. The IRS limits applications to one EIN per responsible party per day.
Getting the EIN is only one step in the compliance process.
Keep the EIN confirmation and your completed Form SS-4 with your business records. The IRS also provides procedures for confirming an EIN if the original notice is lost.
An EIN does not determine every tax filing obligation.
Your requirements can depend on:
For broader planning and compliance, see HOA’s tax planning and preparation services.
This is particularly important for certain foreign-owned U.S. disregarded entities. The IRS explains that a U.S. disregarded entity wholly owned by a foreign person may need an EIN for Form 5472 reporting. That does not mean every foreign-owned U.S. LLC automatically has the same Form 5472 requirement. The entity’s federal classification and reporting circumstances matter.
Form 5472 penalty exposure: If Form 5472 is required and is not filed correctly and on time, the IRS may impose a $25,000 penalty, with additional penalties possible if the failure continues after IRS notification. Foreign-owned U.S. disregarded entities should therefore determine whether Form 5472 applies and maintain the records needed to support the filing.
After obtaining the EIN, maintain accurate books and records for tax reporting and financial management. For businesses that need ongoing financial recordkeeping, see HOA’s bookkeeping and accounting services.
If you are a Pakistani resident who owns or operates a U.S. business, obtaining an EIN does not by itself resolve your Pakistan-side tax or reporting obligations.
Pakistani residents may need to declare foreign assets and foreign-source income in their annual income tax return and Wealth Statement (Form 116) filed with the Federal Board of Revenue (FBR), depending on their circumstances.
Your U.S. entity structure and Pakistan tax position should be reviewed together where cross-border activity is involved. You can discover our guide on business tax planning in Pakistan for the Pakistan-side planning context.
You can generally obtain an EIN for a U.S. LLC without an SSN, even if you are a non-U.S. resident.
For an international applicant, the critical steps are:
An EIN gives the business a federal tax identification number. It does not, by itself, determine the LLC’s complete U.S. tax or reporting obligations.
To get your EIN is an important step, but it may not be the last one. If you are running a U.S. LLC from Pakistan, you may also need to understand your U.S. tax filings, reporting requirements and Pakistan-side obligations. If you are unsure what applies to your business, explore HOA’s U.S. Tax Planning & Compliance Services to understand the next steps.
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