US Tax Attorney Needed – Foreign-Owned Delaware LLC Closure / Form 1065 vs Form 5472 Classification
Worldwide
I need a US tax attorney to help close a dormant Delaware LLC formed in 2025. The LLC has never traded and has had no revenue, employees, or customers. The ownership and tax-classification position needs to be reviewed before any federal tax filings are submitted: The LLC is economically owned 100% by a UAE free-zone company. I am the ultimate owner/controller of the UAE company. The formation provider prepared the EIN application showing 2 LLC members and selected “Partnership.” The formation provider has since confirmed that its system automatically assigned me a 0% membership interest because it required an individual responsible party/member. The operating agreement generated by the provider is inconsistent and does not clearly document the intended ownership structure. The provider confirms that no Form 8832 was filed and no federal tax returns were filed on my behalf. I need the attorney to: Review the SS-4, operating agreement, EIN letter, and correspondence with the formation provider. Determine whether the LLC was actually a partnership for federal tax purposes or a foreign-owned single-member disregarded entity. Determine whether the correct delinquent 2025 filing is Form 1065 or Form 5472 with a pro forma Form 1120. Advise on correcting the IRS entity classification/account if necessary. Advise on reasonable-cause treatment for any late filing. Confirm the correct Delaware dissolution and winding-up process. Confirm the final federal filing required after dissolution. Ideally prepare or review the required federal filings, or coordinate with a CPA/EA who can. The company is dormant and has very limited transactions, mainly formation and registered-agent expenses. I am looking for a fixed-fee engagement, beginning with a written classification opinion/recommendation. Please include: Your US state bar admission. Your experience with Forms 5472 and 1065. Your experience with foreign-owned US LLCs. Whether you personally handle IRS entity-classification corrections. Whether you can prepare/sign the tax filings or work with a CPA/EA. Your fixed price for the initial review and written recommendation. Please do not send a generic proposal. In your response, briefly explain whether you have handled a case involving a foreign corporate owner and an alleged 0% US LLC member.
$500.00
Fixed-price- ExpertExperience Level
- Remote Job
- Ongoing projectProject Type
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- Proposals:5 to 10
- Last viewed by client:2 days ago
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About the client
- United KingdomLondon4:43 AM
- 1 hire, 1 active
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