No SSN? Write “foreign”
Where the responsible party has no SSN and no ITIN, write the word foreign on line 7b of Form SS-4 in place of a number. You do not need to apply for an ITIN first.
Key takeaways
The online tool is off the table
You cannot apply online, so use phone, fax, or mail. Anyone can apply by fax or mail — the phone line is open only if the entity was formed outside the US.
The responsible party must be a person
The individual named on line 7a has to actually control the entity. Naming a parent company there gets the application rejected.
[ Have us fill in the SS-4 with you ]
An incomplete line on the SS-4 buys another IRS request and another wait. Tell us the entity, the state, and who controls it. Call (212) 641-0673 or use the contact form.
We work with founders in every time zone.
01The online tool
Can I apply for an EIN online from outside the US?
No, in almost every case. You can only apply online if all three of these are true:
- The entity was formed in the United States or a US territory.
- Its principal place of business is in the United States or a US territory.
- The responsible party has a valid SSN or ITIN.
Where this trips people up
A founder living abroad who forms a Wyoming LLC meets the first condition and fails the other two, so they cannot apply online even though the company is American. Every other route stays open.
02No SSN, no ITIN
Do I need an ITIN before I can apply for an EIN?
No. Line 7b of Form SS-4 asks for the responsible party’s SSN or ITIN. Where that person has neither and cannot obtain one, the instructions tell you to write the word foreign or N/A instead. The line cannot be left blank, but it does not have to hold a number.
What goes on line 7b
Has an SSN
Enter it on line 7b
Has an ITIN instead
Enter that on line 7b
Has neither, and cannot get one
Write the word “foreign” on line 7b
The Internal Revenue Manual tells IRS staff the same thing: foreign individuals are not required to have an ITIN in order to receive an EIN. So an EIN without a Social Security number is the ordinary route rather than a workaround, and a Form W-7 filed first only adds months.
03Phone, fax, or mail
How to apply for an EIN from outside the US
All three routes are free, and all three work without an SSN on the responsible party line. Anyone can apply by fax or mail. Whether you can use the phone line depends on where the entity was formed.
Three ways to apply without the online tool
| Route | Where it goes | How long it takes |
|---|---|---|
| Phone | 267-941-1099, Monday to Friday, 6am to 11pm Eastern. Not a toll free number. | The length of the call |
| Fax | 855-215-1627 from inside the US, 304-707-9471 from outside it | About 4 business days after the IRS receives the fax, if you give a return fax number |
| Internal Revenue Service, Attn: EIN International Operation, Cincinnati, OH 45999 | About 4 weeks after the IRS receives the form, so allow international post on top |
Formed outside the US
Call 267-941-1099. The phone line is open to you.
Formed in a US state or territory
Use fax or mail. The IRS treats any entity formed in a US state as a domestic case, whatever address you put on the form — so a Delaware LLC run from Lisbon has to fax.
Fax is the fastest route open to a US formed entity. The IRS faxes the EIN back to the number you print on the form, in about four business days. Leave that number off and you wait about two weeks for it by mail.
On the phone, the assistor asks whether you have a completed Form SS-4 and can fax it during the call. If you cannot, they take the details over the phone. Fill the form in before you call either way.
Use one route only. Two applications get you two EINs and a correction to file. From the fourth business day you can also call 800-829-4933 to confirm the number.
04Line 7a
Who has to be the responsible party
The belief
The parent company owns the US entity, so the parent company is the responsible party.What is true
Unless the applicant is a government entity, the responsible party has to be a natural person who controls the entity in fact and can direct its funds. An EIN for a foreign corporation needs an officer named on line 7a. A nominee or a formation agent cannot stand in.Why it matters
An entity on that line does not satisfy the rule, so the route starts again: days by fax, weeks by mail. A rejection does not cost you tomorrow as well, because the one per day cap counts EINs issued rather than attempts.
Not sure who goes on line 7a? Tell us the structure and we will name the responsible party before you file. Call (212) 641-0673.
05After the EIN
What a foreign owned US LLC has to file after getting an EIN
Two obligations start before the first return rather than after it.
Form the entity first
The IRS asks you to register with the state before applying and warns that skipping it causes delays. You need the formation date and state to complete the form anyway.
A single member LLC may still have to file every year
A foreign owned single member US LLC is disregarded for income tax, but has to file in any year it has a reportable transaction with its owner — and money put in to fund the LLC at the start counts as one. Those years take a pro forma Form 1120 with Form 5472 attached. Missing it carries a $25,000 penalty per form per year, with a further penalty for each 30 day period after the IRS asks for it. The return cannot be e-filed.
06EIN from outside the US
Frequently asked questions
Can I get an EIN without an SSN or ITIN?
Yes. The form has a place for exactly that case, and no Form W-7 is needed first. Applying for an ITIN before the EIN adds months and changes nothing about the outcome.
How long does an EIN take from outside the US?
By fax, about four business days. By mail, about four weeks. On the phone route the number is read out during the call, where that route is open to you.
Can a Delaware LLC apply by phone from abroad?
Usually no. Incorporation in a US state settles the question for the assistor, whatever address the form carries, and that caller is pointed at fax or mail.
[ Ask what the LLC owes once it exists ]
The EIN is the easy part. The annual filings that come with a foreign owned US entity are where the penalties are. Send us the structure and we will map it. Call (212) 641-0673 or use the contact form.
No charge for the conversation.
12+ years
serving NYC
150,000+
returns filed
5 star
Google and Yelp
Open
evenings and weekends
From the record
On trust, and on serving founders abroad
“A big part of the reason that people use us is what somebody else has said... Anything having to do with financials is just difficult to trust.”
George Dimov, CPA
“Great service! Super helpful and they even helped complete my Brazilian returns along with my US taxes. I will use them again next year for sure. Experts in international!”
Thaiana Byrne
Google review
Get the SS-4 right before you file
Let us complete the SS-4 with you
Whichever route you use — phone, fax, or mail — a completed form with the right responsible party avoids a second wait. Call (212) 641-0673 or send the contact form. No charge for the conversation.
Reviewed by George Dimov, CPA, New York, NY. Serving clients in all 50 states, 15+ years advising foreign founders and inbound businesses on US federal registration, entity structure and cross border reporting. President of George Dimov, CPA, a New York City firm serving clients across the five boroughs and nationwide.