CASE D-01 · einwithoutssn.com/determinations
Neither SSN nor ITIN — single-member LLC
The flagship case, worked in full. One foreign owner, one member, no SSN, no ITIN — and an LLC that already exists.
ROUTE: FAX — CINCINNATI
Facts as examined
The entity is formed — Articles in hand — and wholly owned by one individual who is not a US person and holds no SSN and no ITIN. The deciding lines of the application, as completed for this case:
Application for Employer Identification Number
Rev. December 2025
Cat. No. 16055N
SPECIMEN — RECREATION OF FORM SS-4 FOR A FICTIONAL ENTITY. NOT A FILED FORM.
Ruling
Online is closed; the paper routes are open. The IRS online application requires the responsible party to hold a valid SSN, ITIN or EIN and is not open to an applicant with no legal residence, principal place of business, or principal office in the United States or its territories. That closes one door, not the building. You do not need to obtain an ITIN first — nothing in the SS-4 instructions makes a personal number a precondition — and you do not need to travel to the United States. The routes the IRS publishes for international applicants are the phone line (267-941-1099), fax, and mail to the EIN International Operation in Cincinnati. For this case the desk rules fax first: a published window and a paper trail. What each line means in the abstract is REF B-3 — Form SS-4, annotated (EIN for Non-Residents); what goes on the lines for this case is below.
The filing, line by line as completed
Line 1 — legal name. Copied exactly as it appears on the formation documents. The IRS instructs you to enter the business name as it appears on your registration or formation documents, and its systems accept only letters, numbers, hyphens and ampersands — symbols are spelled out or replaced as the EIN page directs. A shortened name is Returned, Exhibit 1.
Line 7a — responsible party. The owner, by name — the individual who ultimately owns or controls the entity and its funds. Not the LLC itself (Exhibit 3), and not a nominee: the IRS states that nominees are not authorized to apply.
Line 7b — the whole case. “Foreign.” The Instructions for Form SS-4 (Rev. December 2025) direct an applicant whose responsible party does not have, and is ineligible to obtain, an SSN or ITIN to enter “foreign” or N/A on line 7b — an entry is required. Blank is a stall (Exhibit 2); somebody else's number is misrepresentation. The annotated treatment is Line 7b in The Form, Annotated.
Lines 8a–8c — the LLC lines. Yes, it is an LLC; 1 member; organized in the United States. The member count is not bookkeeping — it drives the default classification in the next line.
Line 9a — type of entity. A domestic single-member LLC is disregarded as an entity separate from its owner by default. Where the EIN is requested for the Form 5472 filing required of a wholly foreign-owned US disregarded entity, the instructions direct: check “Other” and write “Foreign-owned U.S. disregarded entity-Form 5472.” Use the current instructions' exact wording — this line is the one the IRS revises.
Line 10 and the rest. “Started new business,” with the type of business stated; formation date on line 11; December on line 12 for a calendar-year entity; employees answered as the entity actually is — zero is a valid answer. The designee block is completed only if a designee is actually filing for you, and the form is signed: an unsigned SS-4 is a stalled SS-4 (Exhibit 7).
The wait
The phone route, for an eligible international applicant, assigns the number during the call (267-941-1099, Monday–Friday 6 a.m.–11 p.m. Eastern; complete the SS-4 first — the caller must be authorized to receive the EIN and answer questions about the form). Two cautions ride with every window here. The IRS warns that high inventory levels may result in processing delays, so four business days is the published window, not a promise. And a new EIN is usable immediately for most purposes — a bank account, licences, paper returns — but can take up to two weeks to pass IRS TIN matching and e-file systems. All three routes are logged on The Wait. One EIN per responsible party per day: do not fax and then phone the same application “to be safe” (Exhibit 5).
What comes back — and what this case owes next
What returns is the CP 575, the EIN confirmation notice — issued once, never reissued. Guard the original; if it is lost, the replacement document is Letter 147C (REF C-1, EIN for Non-Residents). Then the obligation this case creates: a wholly foreign-owned disregarded entity files Form 5472 attached to a pro-forma Form 1120 every year, reporting transactions with its owner — funding the company counts. Orientation is on After the CP 575; the reference depth is REF D-1, and EIN basics are REF A-1 and REF B-2.
If this desk files it
This is the case EIN Complete ($249) is built for: the SS-4 prepared line by line as above, faxed with the return number on the form, the window tracked against the IRS's published figures, and the CP 575 delivered as the closing document. Fulfillment opens only when it can be walked end to end, so today nothing is for sale — the route in is the launch list. The EIN itself is free from the IRS, and this determination is the whole method if you would rather file it yourself.
Sources: Instructions for Form SS-4 (Rev. December 2025) — lines 7a–7b, 8a–8c, 9a disregarded-entity wording, third-party designee, one-per-day limit; IRS — Employer Identification Number — international routes, fax numbers, windows, TIN-matching lag. Checked against irs.gov on November 5, 2026. EIN Complete is pre-launch: nothing is for sale yet; the $249 package joins by launch list only.