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ITIN or EIN First? What Foreign-Owned Single-Member LLC Owners Must File Before Opening a U.S. Bank Account

If you've formed a U.S. LLC as a non-resident and are now staring at a bank application asking for numbers you don't have yet, you're not alone — this is one of the most common stalling points for foreign founders. The order-of-operations question — ITIN or EIN first? — trips up thousands of Amazon sellers, SaaS founders, and e-commerce owners every year, and getting it wrong can cost you weeks. This guide breaks down exactly what each number does, why the EIN almost always comes first for a single-member LLC, and the sequence that gets your business bank account funded fastest.

Why This Order-of-Operations Question Trips Up Non-Resident LLC Owners

Search "how to open a US bank account as a foreigner" and you'll find dozens of forum threads where someone applied for an ITIN before realizing their LLC needed an EIN, then had to start over with the bank. The confusion is understandable: both are nine-digit numbers issued by the IRS, both show up on tax forms, and both get requested by banks — but they identify completely different things.

An EIN (Employer Identification Number) identifies your business. An ITIN (Individual Taxpayer Identification Number) identifies you, the individual, for U.S. tax purposes. A single-member LLC owned by a non-resident almost always needs the EIN first, and may or may not need an ITIN depending on how the business is taxed and whether you'll personally owe U.S. tax. Mixing up which one unlocks the bank account — and applying for the wrong one first — is the single biggest reason bank onboarding drags into month two or three instead of wrapping up in three to four weeks.

EIN vs. ITIN: What Each Number Actually Does for Your LLC

The distinction matters because a bank doesn't care about your personal tax situation when opening a business account — it cares whether the business itself is a validly registered, IRS-recognized entity. That's what the EIN proves. For a deeper breakdown of what an EIN actually does and whether you need one, see our full explainer on EINs for non-U.S. residents.

Why the EIN Almost Always Comes First for a Single-Member LLC

For a foreign-owned single-member LLC, the EIN is the foundation everything else sits on. Here's why it comes first, structurally:

1. The bank requires it. Every major U.S. bank — Mercury, Relay, Wise Business, and traditional institutions like Chase or Bank of America — requires an EIN to open a business account. None of them ask for your personal ITIN as a precondition for the business account itself.
2. The IRS requires it for compliance, regardless of tax owed. A foreign-owned single-member LLC that's treated as a disregarded entity is still required to file Form 5472 alongside a pro forma Form 1120 annually, and you cannot file either without an EIN. This applies even in years with zero U.S. tax liability.
3. You don't need an SSN or ITIN to get an EIN. The IRS allows a non-resident with no SSN/ITIN to obtain an EIN by phone (for principals with an SSN or ITIN already) or, more commonly for foreign owners with neither, via fax or mail using Form SS-4 with "Foreign" written in the SSN/ITIN field. This is precisely the path that lets non-residents get their LLC operational before ever touching a W-7.

Because the EIN doesn't depend on you having an ITIN, but almost every downstream step — banking, payment processors, business licenses — depends on the EIN, it sits at the top of the sequence for nearly every foreign-owned single-member LLC.

When You Also Need an ITIN — And Why Timing Matters

An ITIN becomes necessary when you, personally, have a U.S. tax filing obligation — not simply because you own a U.S. LLC. Common triggers include:

• You need to file a Form 1040-NR because you have U.S.-source income taxed at the individual level (common if your LLC's default disregarded-entity status means profits flow to your personal return).
• You're claiming a tax treaty benefit to reduce withholding on U.S.-source payments.
• You sold U.S. real property and need to file for a FIRPTA withholding refund — see our guide on how non-resident sellers can legally reduce FIRPTA withholding.
• A bank's compliance team, in rarer cases, requests it during enhanced due diligence, even though it isn't a universal requirement.

Timing matters because ITIN processing through a standard W-7 mail submission to the IRS typically runs 7 to 11 weeks, and that clock doesn't start until you have a qualifying reason to apply — the IRS generally won't issue an ITIN on a standalone basis without an attached tax return or an accepted exception. That's the opposite of the EIN, which you can request as soon as the LLC is formed. If you assume you need the ITIN immediately and apply before you have EIN-based banking or a filing trigger in hand, you can end up waiting on a number you didn't need yet, while your bank application — which only needed the EIN — sits idle.

What U.S. Banks Actually Require to Open a Business Account Remotely

Neobanks built for international founders (Mercury, Relay, Wise Business) and traditional banks differ meaningfully in what they'll accept remotely:

• EIN confirmation letter (IRS Form CP 575 or the 147C verification letter) — required by virtually every bank, remote or in-branch.
• Formation documents — Articles of Organization or Certificate of Formation from the state, plus an operating agreement in most cases.
• Proof of a U.S. business address — this can be a registered agent address in many states, though some banks want a distinct mailing address.
• Government-issued photo ID for the beneficial owner — passport is standard.
• Beneficial ownership information — under the Corporate Transparency Act's BOI reporting requirements (enforced by FinCEN, not directly by banks, though banks often collect similar data for their own KYC).

Notably absent from that list, for most digital-first banks: an ITIN. Mercury and Relay, for example, are built specifically to onboard non-resident founders using EIN + passport + formation documents, without requiring a personal ITIN at account opening. Traditional brick-and-mortar banks are more inconsistent — some branches still ask for an ITIN or SSN out of unfamiliarity with foreign-owner rules, even though it isn't a hard requirement, which is why choosing the right bank is half the battle.

Common Sequencing Mistakes That Delay Bank Account Approval

• Applying for an ITIN before the LLC has an EIN, on the assumption that "you need a tax ID to open a business" — without an attached filing reason, this application likely won't even be accepted by the IRS.
• Submitting a bank application before the EIN confirmation letter arrives, which just returns you to a pending queue instead of an approval.
• Using an EIN obtained via online application — the IRS online EIN assistant is not available to applicants without a U.S. taxpayer ID, so foreign owners must use fax or mail submission of Form SS-4, which takes longer (often 1–4 weeks) than the near-instant online process available to U.S. residents. Not knowing this in advance often adds weeks of unplanned wait time.
• Registering the LLC with a residential or virtual address the bank later flags during KYC, forcing a resubmission.
• Assuming every state processes formation at the same speed — Wyoming and Delaware are typically fast (24–72 hours online), while some states take one to two weeks, which pushes the entire downstream timeline back before you've even reached the EIN step.

Documents to Prepare Before Starting Either Application

Before you file anything, gather these — having them ready prevents nearly every delay in this process:

• Valid passport (unexpired, clear copy)
• LLC formation documents (Articles of Organization/Certificate of Formation)
• EIN application (Form SS-4) with the LLC's legal name, formation date, and responsible party information
• A U.S. mailing or registered agent address
• Operating agreement (not always legally required, but requested by most banks)
• If applying for an ITIN: your Form W-7, the specific document that establishes your filing requirement (e.g., a draft 1040-NR, a real estate closing statement for a FIRPTA claim, or a treaty-benefit statement), and original or certified-copy identification — see what documents you need for an ITIN application for the full breakdown by scenario.

A Step-by-Step Timeline: From Formation to Funded Bank Account

Most foreign-owned single-member LLCs can go from state filing to a funded U.S. bank account in roughly four to six weeks when the EIN is filed correctly and the bank is chosen with non-resident onboarding in mind. The ITIN, when needed, runs on its own separate and later track — tied to your tax return, not your banking.

It's worth remembering throughout this process that EINs and ITINs are issued solely by the IRS; Nolly's role is limited to preparing and organizing the documentation that supports your application, as an independent service working alongside — not on behalf of — the IRS. For a side-by-side comparison of the two numbers in more detail, our ITIN vs. EIN guide is a useful next read once your LLC's structure is settled.

Frequently Asked Questions