US Company Formation from Monaco (2026): No Income Tax at Home but No US Treaty, the US Estate Tax Trap, French and Italian Nationals, Bank Checks After the Grey Listing, and the US LLC vs C-Corp Choice

Monaco residents form US companies for many reasons: a consultant billing American clients, an online brand selling in the USA, a family investing in US property or start-ups, or a Monaco-based founder raising money from US investors. All of it can be done without visiting the USA.

Monaco's own tax position looks simple: no personal income tax for most residents. But that simplicity hides three US-side issues that catch Monaco residents more than most:

• there is no US–Monaco tax treaty, so US withholding taxes apply at full rates with nothing at home to credit them against;
• the US estate tax can take up to 40% of US assets above $60,000 when a non-resident dies, and Monaco residents tend to hold more US assets than most;
• French nationals, and in practice Italian nationals, may be taxed by their home countries despite living in Monaco.

This guide covers each one, then compares US LLC formation with US C-Corp formation.

In short: A Monaco resident can form a US LLC or C-Corporation without visiting, get an EIN without an SSN or ITIN, and apply for a US business bank account remotely. A single-member LLC run from Monaco, with no US office or staff, usually owes no US income tax, and Monaco doesn't tax most residents on it. A US corporation pays 21%, and its dividends to Monaco lose 30% with no relief. US shares and US property in your name can be subject to US estate tax above $60,000. French nationals are generally taxed by France. Monaco was placed on the FATF grey list in 2024, which increased bank checks.

Monaco's tax position

• No personal income tax for residents, except French nationals, who under the 1963 France–Monaco convention are generally taxed by France as if they lived there (with narrow exceptions for long-standing residents).
• Corporate profits tax (ISB) applies mainly to Monaco businesses earning more than a quarter of their turnover outside Monaco, at 25%. Most residents' personal US companies are not Monaco companies, so this rarely applies to them.
• No inheritance tax between parents, children and spouses.
• No wealth tax.

Monaco takes part in automatic exchange of financial account information, so US accounts and companies are visible to the tax authorities of countries that have a claim on you.

The US side: no treaty

Without a treaty, the USA withholds:

• 30% on dividends from a US corporation;
• 30% on US-source royalties;
• 30% on related-party interest (portfolio interest from unrelated borrowers is usually exempt).

For most residents of other countries, a treaty reduces these, and home-country tax gives a credit. A Monaco resident gets neither. So the structure has to avoid unnecessary US withholding.

The US estate tax trap

When a non-resident who is not a US citizen dies, the USA taxes their US-situs assets above an exemption of only $60,000, at rates up to 40%. US-situs assets include:

• shares in a US corporation, including your own Delaware C-Corp or US-listed stocks;
• US real estate held in your own name;
• possibly interests in US LLCs and partnerships, where the rules are less settled.

Monaco has no estate tax treaty with the USA. A Monaco family with a US property, a US start-up stake and a US brokerage account could face a large US estate tax bill on top of the cost of US probate.

Common planning tools include holding US assets through a non-US holding company, using life insurance, or using trusts, but each has its own tax and cost trade-offs. Plan with a US estate tax adviser before buying large US assets. See US estate tax on US company shares for non-residents.

French and Italian nationals in Monaco

• French nationals resident in Monaco are generally taxed by France. A US company owned by a French national living in Monaco is therefore taxed as if owned from France. See the France guide.
• Italian nationals who move to Monaco remain, under Italian law, presumed resident in Italy for tax unless they prove a genuine move, because Monaco is on Italy's list of preferential-tax states. Keep evidence of your life in Monaco. See the Italy guide.
• Other nationals usually look only at Monaco's rules, plus any home-country rules for people who move to low-tax countries.

US citizens living in Monaco remain taxed by the USA on worldwide income; this guide is about non-US owners.

US LLC formation from Monaco

US tax position

The IRS disregards a single-member LLC owned by a non-resident. If you run the business from Monaco and the LLC has no US office, staff or dependent agents, its income is generally not taxed in the USA (see effectively connected income explained). The LLC files Form 5472 with a pro forma Form 1120 every year, with a $25,000 penalty for missing it (see Form 5472 explained).

Example: a yacht interiors consultant

These figures are illustrative.

Luca, a Swiss national resident in Monaco, advises American yacht owners and shipyards on interior design and refits. A Wyoming LLC with a US business account invoices US clients and gives them a Form W-9. Work is done from Monaco and at shipyards in Europe; Luca rarely works inside the USA. Annual revenue is US$300,000.

• USA: no US income tax, because the services are performed outside the USA. The LLC files Form 5472 and a pro forma 1120. If Luca starts spending weeks on US projects, part of the income would become US-source.
• Monaco: no personal income tax.
• Switzerland: no claim once Luca has genuinely left.

US C-Corp formation from Monaco

US tax position

A US corporation pays 21% federal tax plus state tax, files Form 1120 and Form 5472, and its dividends to Monaco are withheld at 30% (see the 21% corporate tax explained). Its shares are US-situs assets for estate tax.

Example: a Monaco start-up raising US money

Take an illustrative case: a Monaco-based team building climate-tech software, supported by a local incubator, plans to raise a seed round from US funds. US investors want a Delaware C-Corporation.

• The Delaware corporation is the parent; a Monaco or French company may employ the team and invoice it for development.
• Profits are reinvested, so the 30% dividend withholding rarely bites in the early years.
• Estate tax: the founders' Delaware shares are US-situs assets. Founders with large stakes consider holding them through a non-US holding company, set up before the shares gain much value.

See raising investment as a foreign founder and LLC vs Inc.

Example: a family investing in US property

A Monaco family buying a Miami apartment for rental and family use can hold it personally, through an LLC, or through a corporation. Holding personally or through a single-member LLC is simple for income tax, but exposes the property to US estate tax above $60,000. A US corporation shields nothing from estate tax, because its shares are US assets too. Families with large US property holdings often use a foreign holding company above the US entity, after taking advice. Rental income is taxed in the USA either way. See real estate investment LLC for foreigners.

Bank due diligence

The FATF placed Monaco on its grey list in June 2024. Monaco worked through an action plan and was expected to be removed at the October 2026 plenary; check the current status. While listed, US banks applied enhanced due diligence to Monaco-linked applicants. Expect questions about:

• source of wealth and source of funds;
• the real business of the US company;
• your nationality and tax residence.

Have a Monaco residence card, a clear business description and supporting documents ready. See why banks reject non-resident applications.

Which state

• Wyoming for a consultant's or online LLC.
• Delaware for a start-up or a corporation.
• Florida or New York for property, in the state where the property is.

See best state for non-residents.

What it costs

UCB's prices include state fees and the first year of registered agent service:

• Wyoming LLC with EIN: $249, or $348 with a US bank account application.
• Delaware corporation with EIN: $358.

A Wyoming LLC costs $121 a year to keep active, or $421 with the annual federal return. See what a US LLC costs every year.

Documents

• Passport.
• Monaco residence card (carte de séjour or carte de résident).
• Proof of address: a SMEG electricity bill, a Monaco Telecom bill or a bank statement.

See US business bank accounts for non-residents and Stripe for non-residents.

Mistakes to avoid

• Ignoring US estate tax on US shares and property.
• Paying dividends from a US corporation at 30% with no relief.
• French nationals assuming Monaco rules apply to them.
• Italian nationals without evidence of a genuine move.
• Working inside the USA for long periods through an LLC.
• Forgetting Form 5472 because the LLC owes no US tax.

Frequently asked questions

Can a Monaco resident form a US company without visiting? Yes. Formation, the EIN and the bank application are all remote.

Do I need an SSN or ITIN? No. The EIN is issued on Form SS-4 without either.

Does my US LLC pay tax anywhere? If run from Monaco with no US presence, usually not in the USA, and Monaco doesn't tax most residents. French nationals are taxed by France.

Is there a US–Monaco tax treaty? No. US withholding applies at full rates, and there is no estate tax treaty either.

What happens to my US company shares if I die? Shares in a US corporation are US assets for estate tax, taxed above $60,000 at up to 40%. Plan ahead.

How UCB can help

We form US companies for Monaco residents remotely: the state filing, EIN, registered agent, US business address and bank application, through our formation, EIN and bank account package. Each year we file the federal return through our US tax filing service. We do not give estate planning, French or Italian tax advice.

Setting up a US company from Monaco? WhatsApp us at +1 315 961 2956 or email enquiries@ucbsolutions.com.