Regardless of the purpose of the LLC, if it is organized under the laws of the United States or of any of the States, it is a U.S. Person as noted by SARempress. As a U.S. Person, it cannot open a bank account without a TIN (or providing documentation that it has applied for one, if the bank's CIP will permit it).
The attorney's opinion notwithstanding, there are no exceptions to that rule.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8