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Argentina · Tax position

How is a US LLC taxed for an Argentine founder?

There is no US–Argentina tax treaty. A foreign participation is generally within Bienes Personales scope even when the company is dormant. And ARCA may look through a structure without real substance.

Where Argentina stands

Verified July 28, 2026

US–Argentina tax treaty
Excludes

Argentina is absent from the IRS index of countries with a US income tax treaty in force. No reduced withholding, no residency tie-breaker.

Bienes Personales
Excludes

A foreign participation is generally within scope of the wealth tax even if the company is dormant and never distributes.

ARCA informational regime
Excludes

Foreign shareholdings fall under the informational regime for foreign holdings. This is a reporting duty, not an optional disclosure.

Substance requirement
Unverified

Where an LLC has no real substance abroad and is operated entirely from Argentina, ARCA may disregard the entity and treat income as Argentine. Fact-specific.

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Dormant does not mean invisible

Founders frequently assume a company that has not traded creates no obligations. For Bienes Personales, the participation itself is generally within scope regardless of whether the LLC distributed anything. That surprises people who formed a company speculatively and then left it idle.

No treaty removes the fallback

Argentina is absent from the IRS treaty index. There is no reduced withholding on US-source payments and no residency tie-breaker to rely on if positions conflict. Advice written for founders in treaty countries — Turkey, Philippines, Egypt, India — does not transfer to Argentina.

Substance is the question that decides everything else

Where a company has no genuine presence abroad and is run entirely from Argentina, the authority may look through it. That is not an obscure edge case in this market; it is the central risk. A US LLC serving real international customers is ordinary commercial structuring. The same LLC used purely to relocate income on paper is not, and no amount of correct filing fixes a substance problem.

Worth knowing before you buy

This is the page where we are least willing to sound encouraging. RazorFile is not a tax adviser and nothing here is advice. Between no treaty, Bienes Personales exposure on a dormant holding, and the substance question, Argentina genuinely requires an accountant who handles foreign structures before you form.

Common questions

Is there a US–Argentina tax treaty?

No. Argentina does not appear on the IRS index of treaties in force. That affects withholding on US-source income and removes the tie-breaker rules that founders in treaty countries can fall back on.

Do I owe Bienes Personales on a company that made nothing?

A foreign participation is generally within scope of the wealth tax even where the company is dormant. Whether and how much you owe depends on your overall position and the thresholds applying in the relevant year — a question for an Argentine accountant, but do not assume dormancy means nothing to report.

What does 'substance' actually mean here?

In practice: whether the company genuinely operates abroad or exists only on paper while all real activity happens in Argentina. Real international customers, real decisions made through the entity and real economic presence all matter. This is fact-specific and it is the question we would most want you to put to a professional.

Form your US LLC from Argentina

Wyoming filing, Registered Agent, and EIN guidance. $100 state fee, filed in one to three business days.

RazorFile files companies. We are not a law firm, bank, or tax advisor, and nothing on this page is legal or tax advice.