I agree with @pk in that this is not the right forum to discuss this type of transaction. There are too many questions that need to be addressed. You need to have a one on one discussion with a tax professional that understands international tax. Additionally, you need to be prepared to answer the following questions:
- You indicate that the HK company holds an interest in the BVI company and the BVI company owns the US LLC. Based on these limited facts, the HK company in fact has an "ownership" the US LLC, just not directly.
- You don't indicate the ownership of the BVI company. Does the HK own all of the BVI?
- You indicate that this is not the first year filing. What has been filed in the past in the US?
- You still haven't indicated the structure of the US LLC. Is this a true LLC (disregarded entity) or is it a corporation?
- What activity does the US LLC have? US and foreign activity.
As you can see, this has some complications and beyond the scope of this forum.
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
