We are a bit unclear on whether an institutional investor needs an ITIN for withholding taxes and remittance to the IRS. It seems that the ITIN is required for opening a U.S. bank account, which we will definitely need, but are unsure if there are alternative options for companies?
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Sheri Chromow answered:
Every foreign investor will ultimately have to obtain a taxpayer ID number. Before you get there you will want to work with a first-rate tax professional to create as advantageous a structure as possible to minimize US taxes payable. Depending on the structure you and your advisor agree on, which will depend on factors specific to your company, you will create the right structure for your holdings.