BOI Reporting for Foreign-Owned LLCs: Special Considerations

If you're a foreign founder with a US LLC, the FinCEN BOI report has some unique requirements you need to be aware of.

You're almost certainly a beneficial owner

As the foreign owner of a US LLC, you exercise substantial control and/or own 25%+ of the entity. You are a beneficial owner and must be reported.

ID document requirements

FinCEN accepts the following ID documents:

• •Non-US passport — This is the most common for international founders

• •US driver's license

• •State-issued ID

If you don't have a US-issued document, you must provide a non-US passport AND a secondary document showing proof of US address (if you have one).

Important: You must upload an image of the ID document. Make sure it's clear and legible.

Foreign addresses are acceptable

Unlike some IRS forms, the BOI report allows foreign residential addresses for beneficial owners. You don't need a US address.

Company applicant vs. beneficial owner

The BOI report also asks about "company applicants" — the person(s) who filed the formation documents. This could be:

• •You, if you filed directly
• •A registered agent or attorney who filed on your behalf

Companies formed before 2024 do not need to report company applicants.

Multiple entities

If you own multiple US LLCs, each one needs its own BOI report. There's no consolidated filing.

Updating the report

If your information changes (new address, new passport, change in ownership), you must file an updated report within 30 days. This is an ongoing obligation, not a one-time filing.