How to Start a US LLC From Hong Kong

On the currency side, the Hong Kong dollar has been pegged to the US dollar within a narrow band, roughly HK$7.75 to HK$7.85 per USD, since 1983, one of the longest-running currency pegs in the world. For a Hong Kong founder moving money between a local account and a US LLC's Mercury or Relay account, this provides a level of exchange-rate predictability most other founders in this series don't have, though transfers still move as standard international wires subject to normal banking documentation and KYC. It's a background stability advantage rather than a formal FX exemption, but it removes a category of planning that founders in freely floating-currency countries have to think about.

Despite maintaining a network of more than 50 comprehensive tax treaties with other countries, Hong Kong has no bilateral income tax treaty with the United States, a genuine gap given how extensive Hong Kong's own treaty network otherwise is. What exists instead is a narrower Tax Information Exchange Agreement (2014) and a FATCA intergovernmental agreement (2014), both focused on information sharing rather than double-taxation relief. In practice, this matters less for a typical single-member LLC than the missing treaty might suggest, since a non-resident-alien-owned LLC earning non-US-source income usually owes $0 US federal tax to begin with, leaving little for a treaty to relieve regardless of whether one exists.

Putting it together: form the LLC (Wyoming and Delaware remain the two most common choices), get the EIN using the international applicant line above, open a Mercury or Relay account without either restricting Hong Kong, and take genuine comfort in the fact that Hong Kong's tax position on your LLC's income is about as simple as this entire series gets, no individual CFC regime, no FSIE exposure for a personally-owned LLC, and a stable currency peg to work with. The one thing worth planning around is the missing US treaty, which matters more if the business scales into US-source income than it does for a typical foreign-facing LLC today.

Hong Kong's status as one of Asia's premier financial and business hubs has made a US LLC a natural complement for Hong Kong-based founders building SaaS products, e-commerce stores, and consulting practices for global clients. For these founders, a US LLC offers direct Stripe and PayPal access as a genuine US entity, and formation that's simpler than establishing a Hong Kong company specifically to serve US-facing clients, even though Hong Kong's own company registration process is already famously fast. What makes Hong Kong's version of this story unusually simple compared to most countries covered in this series is that its territorial tax system, combined with a 2023 reform that gets widely misunderstood, leaves almost no personal tax question for a solo founder to resolve. Understanding exactly why that reform doesn't apply to you is worth five minutes before you assume otherwise.

The one Hong Kong reform that gets frequently misread is the refined Foreign-Sourced Income Exemption (FSIE) regime, effective January 1, 2023 and expanded further in 2024, introduced specifically because the EU threatened to blacklist Hong Kong over its territorial system. It's easy to see references to this reform and assume it now taxes a Hong Kong resident's foreign company income more broadly. It doesn't, at least not for you: the FSIE regime explicitly excludes individual taxpayers from its scope. It applies only to entities that are members of a multinational enterprise group carrying on a trade, profession, or business in Hong Kong, meaning Hong Kong companies, not individuals who personally own a foreign entity like a US LLC. If you own the LLC directly as an individual, this entire reform simply doesn't apply to your situation.

Getting an EIN as a Hong Kong founder works exactly like it does for any other non-US resident. Without a US Social Security Number or ITIN, you can't use the IRS's online EIN application — you'll file Form SS-4 and either call the IRS's international applicant line (267-941-1099, staffed 6am-11pm ET, for international applicants only) to receive the EIN over the phone, or fax the SS-4 (855-215-1627 from within the US, 304-707-9471 from outside) for a roughly 4-business-day official turnaround that often takes 1-2 weeks in practice. Mailing to Cincinnati, OH takes 4-5 weeks and should be a last resort. On Line 7b, write 'Foreign' or 'N/A' rather than leaving it blank. The responsible party listed must be the actual Hong Kong owner, not EasyBrise or any formation agent. If you lose your CP 575 confirmation notice, request Form 147C, a letter, not a duplicate, instead. Don't skip Form 5472 plus a pro forma 1120 each year; the penalty for missing it starts at $25,000.

On the banking side, Hong Kong is not on Mercury's or Relay's prohibited-country list, and Hong Kong founders go through the same standard non-resident application process, passport, LLC formation documents, and EIN, as founders from most other countries in this series. There's no distinct Hong Kong-specific hurdle at the account-opening stage.

Even for the companies the FSIE regime does cover, its reach is narrower than the general headlines suggest. It applies only to four specific categories of passive income, dividends, interest, income from intellectual property, and disposal gains on equity and other property, and only when that income is actually received in Hong Kong, meaning remitted, used to settle a Hong Kong debt, or used to acquire property brought into Hong Kong. Active business income, and any of these four categories left outside Hong Kong entirely, still fall outside the FSIE regime. Covered entities can also claim an exemption by meeting economic substance requirements or, for IP income, a nexus-based test. None of this changes the individual-level answer above, but it's useful context if you ever restructure to hold the LLC through a Hong Kong company.

Hong Kong taxes profits on a territorial basis: only income that arises in or is derived from Hong Kong is subject to profits tax, currently up to around 16.5% for corporations, with foreign-sourced income falling entirely outside the tax base for both individuals and most businesses. There is no personal capital gains tax, no dividend tax, and no separate individual-level CFC regime attributing a foreign company's income to a Hong Kong resident who owns it, unlike the majority of countries covered elsewhere in this series. A Hong Kong resident who personally owns a US LLC running an active, foreign-facing business isn't subject to any Hong Kong mechanism that reaches into the LLC's income the way ownership-based CFC tests do in Poland, Portugal, Sweden, or Turkey.