US resident form LLC with foreign partner

[Ally Gao]

Hi BP experts, I am newbie from TX. I am planning to register a LLC with a friend who is a foreigner. I have a few questions and hoping to hear your expert advice. 1. Does my foreign partner need to apply ITIN for tax purpose? If so, should we register the LLC first? Does she need a US bank account too? 2. What would be the tax implications for both of us? I am assuming that she only need to pay IRS for the portion of what she earned in US through the LLC. And if we reinvest all the earnings, we both won't have income from LLC, thus no personal tax, but corporate tax. Am I correct? What would be the tax rate for foreign partner? 3. I heard about the series LLC vs standard LLC. My understanding of series LLC is that it will have a master LLC and series of LLCs under the master LLC. Each series LLC can have its own property, asset and liability protection etc. However, they must be proven to be independent from the rest of the series LLCs in terms of operations and/or accounting. I wonder if the series LLC will complicate tax return and accounting. Would there be extra cost too? Is it worth it? 4. Can someone recommend a good CPA and RE attorney who is familiar with involving foreign partner and know the rules in Texas? Thank you very much for reading my message and I am looking forward to hearing from you all! Have a great day everyone! Ally