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LLC vs S-Corp vs C-Corp for Non-Residents

If you are not a US citizen or resident, an S-Corporation is not available to you. The tax code restricts S-Corp shareholders to US citizens and US resident aliens, so the real decision for a non-resident is between an LLC and a C-Corporation.

Choose an LLC if you are a founder, freelancer, agency or e-commerce seller who keeps the profit: no entity-level tax, far lighter compliance, and it can elect corporate treatment later if circumstances change. Choose a C-Corporation if you plan to raise venture capital, grant stock options, or retain profits inside the business. Roughly nine out of ten non-resident founders we work with are better served by an LLC.

The three structures compared

LLC, S-Corporation and C-Corporation compared for non-US residents
 LLCS-CorpC-Corp
Open to non-residentsYes - availableNo - not availableYes - available
Entity-level federal taxNone; profit passes throughNone; profit passes through21% on profit
Double taxationNo - does not applyNo - does not applyYes, on dividends
Owner limitUnlimited, any nationality100, US persons onlyUnlimited, any nationality
Federal returnPro-forma 1120 + 5472, or 10651120-S1120
Compliance weightLightModerateHeaviest: board, minutes, resolutions
Raising venture capitalDifficultDifficultStandard
Stock options for staffNo - not availableLimitedYes - available

Why non-residents cannot use an S-Corp

An S-Corporation is not a type of company. It is a tax election a corporation or LLC makes with the IRS, and the eligibility rules are strict: no more than 100 shareholders, one class of stock, and every shareholder must be a US citizen, a US resident alien, or certain trusts and estates. A non-resident alien shareholder invalidates the election immediately, and the entity reverts to C-Corporation treatment with back tax owed.

If you become a US resident later, an S-Corp election may become available. Until then, treat it as out of scope.

Choose an LLC when

  • You are selling services, software or products and keeping the profit yourself.
  • You want the lightest possible annual compliance.
  • You want to avoid paying US corporate tax on profit that is not effectively connected to a US trade or business.
  • You value the option to elect corporate taxation later without re-forming the company.

Choose a C-Corp when

  • You are raising from institutional investors, an accelerator, or on a SAFE. Almost all of them require a Delaware C-Corp.
  • You need to grant stock options to employees or advisers.
  • You intend to retain profits in the company rather than distribute them, so the 21% corporate rate beats the personal rate that would otherwise apply.
  • You want a single, familiar structure for many shareholders across many countries.

The filing obligation nobody escapes

Whichever you pick, the entity files. A foreign-owned single-member LLC with zero revenue still files a pro-forma Form 1120 with Form 5472 attached, and the penalty for missing that is $25,000 per year. A C-Corporation files Form 1120 whether or not it profited. A multi-member LLC files Form 1065 and issues a Schedule K-1 to each member. Filing a return showing nothing is free; not filing is what costs money.

Frequently asked questions

Can a non-US resident own an S-Corporation?

No. An S-Corporation may only have shareholders who are US citizens or US resident aliens. A non-resident alien cannot be a shareholder, so for anyone living outside the US the real choice is between an LLC and a C-Corporation.

Should a non-resident choose an LLC or a C-Corp?

Choose an LLC if you are a founder, freelancer, agency or e-commerce seller keeping the profit yourself: it avoids entity-level tax and has far lighter compliance. Choose a C-Corporation if you plan to raise venture capital, issue stock options to employees, or retain profits inside the company.

Is an LLC taxed twice?

No. A single-member LLC is disregarded and a multi-member LLC is taxed as a partnership, so profit passes through to the owners and is taxed once. A C-Corporation is taxed at 21% on its profit and its shareholders are taxed again on dividends.

Does a foreign-owned LLC still have to file?

Yes. Even a disregarded LLC with no profit files a pro-forma Form 1120 with Form 5472 attached. The penalty for missing it starts at $25,000.