Does an LLC Need to File Form 720?
Do you need to file Form 720 for your LLC? Only if the LLC does something that triggers a listed excise tax. The IRS test never mentions entity type. It asks whether you are liable for, or responsible for collecting, a federal excise tax listed in Form 720, Parts I and II. A one-person consulting LLC with no such activity doesn’t meet that test. A one-person LLC that runs a tanning salon does.
So the useful question isn’t “we are an LLC, what do we file?” It is “what does this LLC actually do?” If you want a quick answer, the Form 720 eligibility checker maps activities to IRS Nos.
Which LLC activities trigger Form 720?
These situations are made-up illustrations of rules in the IRS sources.
| What the LLC does | Form 720? | Why |
|---|---|---|
| Runs a tanning salon | Yes, IRS No. 140 | The person receiving payment must collect and remit 10% and file |
| Operates charter flights | Yes, IRS No. 26 | The person receiving payment for air transportation collects, submits, and files |
| Makes the first retail sale of a heavy tractor | Yes, IRS No. 33 | 12% of the sales price on the first retail sale of each taxable unit |
| Imports taxable truck tires and sells them | Yes, IRS Nos. 108, 109, or 113 | Tax on tires sold by the manufacturer, producer, or importer |
| Makes and sells fishing reels | Yes, IRS No. 41 | The manufacturer, producer, or importer pays 10% of the sales price |
| Takes customers' cash for transfers as a remittance provider | Yes, IRS No. 155 | Providers collect the 1% tax from certain senders, deposit, and file |
| Sponsors a self-insured health plan or an HRA | Yes, IRS No. 133, unless the HRA is an excepted benefit | The employer is the plan sponsor of a single-employer plan, and the fee is reported annually |
| Buys a fully insured group health policy, with no HRA or other self-insured coverage | Not for the PCORI fee | The IRS chart places the fee on the issuer when coverage is insured |
| Provides consulting or software, with no listed activity | No | No listed excise tax liability or collection duty |
One mix-up deserves a mention. Owning and operating a heavy truck is a different subject from selling one. The IRS’s Heavy Highway Vehicle Use Tax Return is Form 2290, a separate form. The 12% tax on Form 720 attaches to the first retail sale of heavy trucks and tractors.
Health benefits are another. An LLC with a small HRA can be a Form 720 filer even though it sells nothing taxable, and it would file the annual PCORI fee return rather than four quarterly ones.
Which EIN does an LLC use on Form 720?
This is where LLC owners most easily go wrong, because excise tax doesn’t follow the income tax treatment.
A single-owner LLC may be disregarded for other federal tax purposes. Excise tax is different. The instructions say that eligible single-owner disregarded entities are treated as separate entities for excise tax and reporting purposes. They must do all of the following under their own EINs, and these actions can’t take place under the owner’s taxpayer identification number:
- Pay and report excise taxes (other than IRS Nos. 31, 51, and 117)
- Register for most excise tax activities
- Claim any refunds, credits, and payments
In practice, a made-up Sample Tan LLC, owned by one person, enters Sample Tan LLC’s EIN on Form 720, not the owner’s Social Security number or the EIN of the owner’s other company. If you aren’t sure whether the LLC already has an EIN, the instructions direct you to the IRS Business and Specialty Tax Line at 800-829-4933. To get a new number, apply on the IRS EIN page.
The IRS sources we used don’t set out a separate rule for multi-member LLCs. The general test applies: whoever is liable or responsible for collecting files, and Form 720 asks for that filer’s EIN.
Who signs for the LLC, and who answers if tax goes unpaid?
Form 720 must be signed by a person authorized by the entity. The instructions don’t limit that to a particular title, and the form has a line for your title.
Don’t assume the LLC structure keeps unpaid collected tax away from you personally. For communications, air transportation, and indoor tanning taxes that are collected but not paid over, or willfully not collected, the trust fund recovery penalty equals the full unpaid tax. It can fall on anyone the IRS finds responsible who acted willfully. Pub. 510 describes a responsible person as anyone with the duty and ability to direct, account for, or pay over the money, and says signature power on the business checking account could be a significant factor. The IRS sources we used don’t address LLC members by name, so if you run the money at a small LLC, take that description seriously.
What should an LLC do next?
If your LLC does have a listed activity, take these steps in order.
- Confirm the LLC has its own EIN.
- Find its IRS Nos. and check whether they fall in Part I, which generally needs semimonthly deposits when net liability exceeds $2,500 for the quarter, or Part II, which is generally paid with the return. The guide to who must file by business type can help.
- Note the due date for the quarter. The next two are Monday, November 2, 2026, and Monday, February 1, 2027. A PCORI-only LLC reports once a year on the second-quarter return.
- If the activity has ended and you won’t owe in future quarters, file a final return and check the Final return box.
- Keep supporting records for at least 4 years, as the instructions describe.
When the LLC is ready, you can file Form 720 online with EasyFile720. You add the LLC’s details, enter your figures for the Part I or Part II categories that apply, and sign electronically. It is free to create an account, and you pay $39.95 per filing when you file. A business filing every quarter can use the Full Year Plan, at $139.99 per business for 4 filing credits. Credits never expire and can be used for any of your businesses, and past returns stay saved in your account.
FAQ
Can a single-member LLC report excise tax under the owner's Social Security number?▼
Generally no. Eligible single-owner disregarded entities report under their own EINs, apart from IRS Nos. 31, 51, and 117. How the LLC reports income tax is a separate matter.
My LLC never owed excise tax. Do I need to send a zero return?▼
The filing test is based on having a listed liability in the current quarter, or in a prior quarter without a final return. If neither has ever applied, that test isn't met.
I own two LLCs. Is it one Form 720 or two?▼
If each LLC has its own liability, each reports under its own EIN, so expect a separate return for each. EasyFile720 Full Year Plan credits can be used for any of your businesses.
Which LLC owes when several employers share one self-insured plan?▼
It depends on the plan document, which can identify or designate a plan sponsor. If none is identified or designated, each employer that established or maintains the plan files a separate Form 720.
File Form 720 online
Create a free account with no credit card and build your return. You pay $39.95 only when you file. EasyFile720 is an IRS-authorized e-file provider, and you get an acknowledgment when the IRS accepts your return.
Sources: Instructions for Form 720 (Rev. June 2026); Publication 510 (Rev. December 2025); 26 CFR 46.4376-1; IRS PCORI chart of coverage types; IRS Excise Tax e-File and Compliance page. General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.
