The IRS rule in one sentence If the responsible party does not have and is ineligible to obtain an SSN or ITIN, enter “foreign” or “N/A” on line 7b. The IRS says an entry is required. If that condition does not apply, do not use the shortcut merely because the person lives outside the United States.

Use this decision sequence

  1. Identify the responsible party. Line 7a is the individual who ultimately owns or controls the entity or exercises ultimate effective control.
  2. Does that individual already have an SSN or ITIN? If yes, enter that number on line 7b.
  3. If not, are they ineligible to obtain either number? Only when both “does not have” and “is ineligible” are true does the current instruction authorize “foreign” or “N/A.”
  4. Enter something. Leaving line 7b blank does not follow the published December 2025 instruction.

These rules come directly from the IRS instructions for lines 7a–7b.

“Foreign” and “N/A” have the same stated use

The IRS permits either entry under the same eligibility condition. Its instructions do not state a preference between the two. Use one clearly and consistently; do not enter both an identifier and “foreign.”

Has an SSN or ITINEnter the number

Foreign residence does not replace an existing U.S. taxpayer identifier.

No number + ineligible“foreign” or “N/A”

This is the narrow exception stated by the IRS.

Line 7a still needs a real person

Except for a government entity, the responsible party must be an individual—a natural person—not another LLC, corporation, registered agent, nominee or formation service. The IRS defines this person by ultimate ownership or control over the entity and its assets.

Do not put the LLC’s EIN on line 7b The entity applying for an EIN cannot serve as its own responsible party. The published exception allowing an EIN on line 7b is for a government entity, not an ordinary LLC.

This entry does not classify the LLC

Writing “foreign” on line 7b describes the responsible party’s identifier situation. It does not turn a U.S.-organized LLC into a foreign entity, elect a tax classification, or answer line 9a. The IRS states separately that line 9a is not a tax-classification election.

Common line 7b mistakes

  • Using “foreign” solely because the owner is not a U.S. citizen.
  • Leaving line 7b empty when the exception applies.
  • Listing a company or nominee as the responsible party on line 7a.
  • Entering the new LLC’s EIN on the application for that same EIN.
  • Assuming line 7b decides whether the application goes to a domestic or international fax number. Fax routing follows the residence, principal-business and principal-office rules in the SS-4 instructions.

What the IRS does not decide for you

The SS-4 instructions do not provide a personalized eligibility determination for an SSN or ITIN. If you are uncertain whether the responsible party is eligible, resolve that question before relying on “foreign” or “N/A.” This guide cannot make that determination.

Official IRS sources Read the current Instructions for Form SS-4 and the official Form SS-4 download page before filing. This page summarizes the December 2025 instructions; it is not an IRS ruling about your eligibility.