U.S. Tax Advisor Needed for Foreign-Owned LLC (5472, 1120, ECI Positioning & Compliance)
I am a non-U.S. resident and owner of a single-member U.S. LLC seeking an experienced tax professional to validate tax positioning and ensure full IRS compliance for the 2025 tax year.
Based on my current understanding, the LLC’s income is likely non-U.S. sourced (no ECI), and filing should consist of Form 5472 with a pro forma Form 1120.
However, I am specifically looking for an expert who can review, confirm, and defensibly support this position, not just prepare forms.
This role is best suited for someone with deep experience in foreign-owned U.S. entities and cross-border tax analysis.
Responsibilities
Analyze my fact pattern to determine whether a U.S. trade or business (ECI) was triggered
Confirm proper tax treatment of income based on where services were performed
Provide clear guidance on whether Form 1040-NR is required
Prepare and/or file:
Form 5472
Pro forma Form 1120
Review and correctly classify:
Owner’s draw transactions
Any personal-to-business transfers (e.g., capital contributions vs loans)
Ensure accurate reporting of related-party transactions
Advise on documentation and positioning for audit defensibility
Confirm whether filing must be done manually or can be submitted electronically
Requirements
Demonstrated experience with foreign-owned single-member U.S. LLCs
Strong technical understanding of:
Form 5472 and pro forma 1120
Effectively Connected Income (ECI)
U.S. trade or business determination
Experience advising non-resident individuals with international operations
Ability to clearly explain tax treatment and reasoning (not just file forms)
High attention to detail and compliance accuracy
Nice to Have (Optional)
CPA or EA designation
Experience with digital nomads / remote-first businesses
Familiarity with prior-year manual IRS filing requirements
Project Details
Scope: Advisory + tax filing
Timeline: Flexible, but completion required before filing deadline
Potential for ongoing advisory relationship depending on fit
Application Instructions
To apply, please answer the following briefly
How do you determine whether a foreign-owned LLC has triggered ECI?
Have you personally handled Form 5472 filings for non-resident LLCs?
Please keep responses concise and specific.
"If you read the entire job post, please include the word "green" in your title so I know you read everything."
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