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Foreign Disregarded Entities

Form 8858 Filing for Foreign Disregarded Entities

Form 8858 is required from US persons who own foreign disregarded entities (FDEs) — such as certain single-member foreign LLCs that are treated as disregarded for US tax purposes. It's also required when a controlled foreign corporation (CFC) or foreign partnership owns an FDE. The form requires detailed financial information about the entity and the penalty for non-filing is $10,000 per form per year.

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Who this is for

  • US citizens or green card holders who own a single-member foreign LLC classified as a disregarded entity
  • Americans who set up a foreign operating structure in their country of residence
  • US persons whose wholly-owned foreign entity is ignored for US federal income tax purposes
  • Those operating through foreign structures in countries like Estonia (e-Residency), Ireland, or Singapore

What this filing may involve

Every situation is different. The forms below commonly apply — your specific filing may vary.

  • 1 Form 8858 — Information Return of US Persons with Respect to Foreign Disregarded Entities
  • 2 Form 5471 — if the FDE is owned by a controlled foreign corporation
  • 3 Schedule C or Schedule E — the FDE's income flows through to your personal return
  • 4 Form 1040 with all pass-through income from the disregarded entity

Documents usually needed

  • 📄 Foreign entity formation documents (certificate of incorporation or registration)
  • 📄 Entity financial statements (profit and loss, balance sheet)
  • 📄 Country of organization and type of entity
  • 📄 Details of the entity's activities and transactions with you

How Nomadic.Tax works

AI-assisted preparation with licensed professional review — every time.

1

We confirm whether your foreign entity qualifies as a disregarded entity for US tax purposes

2

Form 8858 is prepared with the entity's financial data and required disclosures

3

The entity's income is correctly reflected on your Form 1040

4

A licensed CPA reviews the complete international reporting package before filing

When human review matters

  • ⓘ  Default classification rules determine whether a foreign entity is disregarded or classified as a corporation — the entity type and country matter
  • ⓘ  If the entity has more than one owner, it cannot be disregarded and may require Form 8865 or 5471 instead
  • ⓘ  E-Residency Estonia OÜ companies owned by a single US person are a common Form 8858 scenario
Authority Guide

Deeper reading on NomadIcTax.org, our educational resource site

Form 8858 Guide — Foreign Disregarded Entity Reporting →

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Relevant plans

Choose the package that best fits your situation, or view all plans.

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Expat
$499
For Americans living abroad — FEIE, foreign tax credits and FBAR included.
  • ✓  Everything in Premier
  • ✓  Foreign Earned Income Exclusion (Form 2555)
  • ✓  Foreign Tax Credit (Form 1116)
  • ✓  FBAR filing (FinCEN 114) included
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Investor
$599
For expat investors and landlords with income on top of work or business.
  • ✓  Everything in Expat
  • ✓  Schedules D & E for investments and rentals
  • ✓  Foreign asset reporting (Form 8938)
  • ✓  FBAR filing (FinCEN 114) included
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Frequently asked questions about Form 8858 Filing for Foreign Disregarded Entities

What is a foreign disregarded entity?

A foreign disregarded entity (FDE) is a foreign business entity with a single owner that is not treated as a corporation for US tax purposes — it's 'disregarded' as separate from its owner. Single-member LLCs in many countries can qualify as FDEs if the appropriate classification applies.

How is Form 8858 different from Form 5472?

Form 5472 is filed when a US entity (like a US LLC) is owned by a foreign person. Form 8858 is filed when a US person owns a foreign disregarded entity. Both relate to disregarded entities, but in opposite ownership directions.

What is the penalty for not filing Form 8858?

$10,000 per form per year. If not corrected after IRS notice, an additional $10,000 per 30-day period applies. The filing is mandatory even if the entity had no income.

Related filing services

Form 5471 for US Owners of Foreign Companies → View filing service US Filing for Americans with Foreign Companies → View filing service US Expat Tax Filing → View filing service See All Pricing & Plans → View pricing & packages

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