Form 5472 Instructions: How to Fill Out Form 5472 for a Foreign-Owned LLC, Part by Part

TL;DR

Form 5472 asks three things: who your LLC is, who owns it, and what money moved between the two of you during the year. For a foreign-owned single-member LLC, the answers go in Parts I, II, III and V (Parts IV, VI and VII are mostly “no” or blank). You attach the form to a pro forma Form 1120 with “Foreign-owned U.S. DE” written across the top and mail or fax the package to the IRS in Ogden, Utah. The instructions below walk each part at the level of what a typical dormant or low-activity LLC actually writes, then cover the address, the deadline, and what goes wrong when people do it themselves.

Everything here is drawn from the IRS Instructions for Form 5472 (Rev. December 2024) and the December 2023 form. Where the instructions use a specific phrase, we quote it.

What the IRS instructions actually require

The official purpose statement: Form 5472 is used “to provide information required under sections 6038A and 6038C when reportable transactions occur during the tax year of a reporting corporation with a foreign or domestic related party.”

Three definitions do the work for an LLC owner:

• Reporting corporation — includes “a 25% foreign-owned U.S. corporation (including a foreign-owned U.S. disregarded entity (DE)).” Your single-member LLC owned by a non-U.S. person is a foreign-owned U.S. DE, so it is a reporting corporation even though it is not a corporation for any other tax purpose.
• Related party — includes any direct or indirect 25% foreign shareholder. For a single-member LLC that is you, the owner.
• Reportable transaction — any Part IV item paid or received in money, “any transaction listed in Part V,” or any Part VI nonmonetary transaction.

Part V is what catches “dormant” LLCs: it covers “amounts paid or received in connection with the formation, dissolution, acquisition, and disposition of the entity, including contributions to, and distributions from, the entity.” If you paid the state filing fee from your own card, that is a reportable transaction. Why “no activity” almost never means “no Form 5472” covers that trap in detail.

Before you start: what you need on the desk

1. The LLC’s EIN. Item B of the pro forma 1120 and line 1b of Form 5472 both need it. If you do not have one, a foreign owner can get an EIN without an SSN — but do not wait for the EIN to start compiling the numbers.
2. The owner’s foreign taxpayer identification number (FTIN). The instructions say a foreign-owned U.S. DE “must enter” an FTIN for each direct and ultimate foreign owner, and if there is none, enter “None” or “N/A”.
3. A list of every payment between you and the LLC, in U.S. dollars, with the exchange rates you used. The instructions require “a schedule showing the exchange rates used” for Part IV amounts; keep one for Part V too.
4. Formation documents — articles or certificate of organization, with the state and date.
5. Last year’s Form 5472, if any, so the reference ID number and FTIN stay consistent year to year.

Form 5472 part by part

The table gives the whole form at a glance; the sections after it explain each line for a foreign-owned single-member LLC.

Header: the tax year

Enter the beginning and ending dates of the LLC’s tax year. The instructions say a foreign-owned U.S. DE “has the same tax year used by its owner for U.S. tax filing requirements or, if none, the calendar year.” For nearly every non-resident owner that is the calendar year. The same dates must appear on the pro forma 1120.

Part I — Reporting corporation (lines 1a to 3)

• 1a Name and address. The LLC’s legal name as registered with the state. For a foreign address, the instructions say to enter “city, province or state, and country” and “do not abbreviate the country name.”
• 1b EIN. The LLC’s EIN, not the owner’s.
• 1c Total assets. Domestic reporting corporations take this from Form 1120 item D. Enter the LLC’s year-end assets; a dormant LLC with an empty bank account can be $0.
• 1d–1e Principal business activity and code. Describe what the LLC does (or is set up to do) and pick the six-digit code from the Form 1120 instructions list.
• 1f Total value of gross payments on this form. The total of Part IV lines 22 and 36 plus the value of Part VI items, and for a DE, Part V as well. If your only transactions are Part V items, this line reflects those amounts.
• 1g Number of Forms 5472 filed. The instructions require “a separate Form 5472 for each foreign or U.S. person who is a related party” with reportable transactions. One owner, one form: enter 1.
• 1h Total value on all forms. Same as 1f when you are filing one form.
• 1i Consolidated filing. Leave blank.
• 1j Initial year. “Check the box if this is the first year the U.S. reporting corporation has filed a Form 5472.”
• 1k Number of Parts VIII. 0 for an LLC with no cost sharing arrangement.
• 1l Country of incorporation / 1m Date of incorporation. “United States” and the date the state formed the LLC.
• 1n Country(ies) where the LLC files an income tax return as a resident. For a disregarded entity that files no income tax return anywhere, preparers commonly enter “None”; if the LLC is taxed as resident somewhere, list it.
• 1o Principal country where business is conducted. Where the work is actually done. The instructions forbid entering “worldwide”.
• Line 2. Check it: a foreign person owns at least 50% of the LLC.
• Line 3. Check it: “Check this box if you are a foreign-owned U.S. DE.” Missing this box is the single most common defect on self-prepared forms.

Part II — 25% foreign shareholder (lines 4a to 7e)

The instructions: “For a foreign-owned U.S. DE, report the information for the foreign owner on the lines provided for the 25% foreign shareholder.”

• 4a Name and address of the owner — an individual’s home address abroad, or the foreign company’s registered address if the owner is a company.
• 4b(1) U.S. identifying number, if any. An SSN or ITIN if you have one; most non-resident owners do not, and that is fine. Do not apply for an ITIN just for this line.
• 4b(2) Reference ID number. Required “only in cases where no U.S. identifying number was entered.” You make it up: alphanumeric, no spaces or special characters, up to 50 characters, and “the same reference ID number must be used consistently from tax year to tax year.”
• 4b(3) FTIN. Mandatory for DEs: your home-country tax number (for example a Philippine TIN, an Indian PAN, a UK UTR). If none exists, write “None” or “N/A”.
• 4c Principal country where business is conducted; 4d Country of citizenship; 4e Country where you file an income tax return as a resident. Answer for the owner personally.
• Lines 5a–7e. For a second direct owner and for ultimate indirect owners. A single individual owning the LLC directly leaves these blank. If a foreign company owns the LLC, that company goes on 4a and the individual who ultimately owns the company goes on 6a.

Part III — Related party (lines 8a to 8g)

The instructions are explicit: “All filers must complete Part III even if the related party has been identified in Part II as a 25% foreign shareholder.” So you repeat yourself.

• Check “foreign person” in the heading.
• 8a your name and address again; 8b(1)–(3) the same identifying numbers as Part II.
• 8c–8d the related party’s business activity and code. For an individual owner, describe your occupation.
• 8e Relationship. Check “25% foreign shareholder” (and any other box that applies).
• 8f–8g the country where the related party does business and files as a resident.

Part IV — Monetary transactions (lines 9 to 36)

Part IV must be completed when the Part III related party is a foreign person. It lists categories of money received (lines 9–21, totalled on 22) and money paid (lines 23–35, totalled on 36). A dormant LLC usually has nothing here, because formation costs and capital contributions belong in Part V, not Part IV. Lines that do come up for small LLCs:

• Line 17 / 31 — amounts borrowed from, or loaned to, the owner. Report the beginning and ending balances (outstanding balance method) or a monthly average.
• Line 29 — consideration paid for services. If the LLC paid its owner for work, it goes here.
• Line 32 — interest paid on an owner loan.
• Line 21 / 35 — other amounts received / paid not covered by the named lines.

Two reliefs in the instructions help small filers: a “reasonable estimate” is acceptable when actual amounts are not determinable (at least 75% but not more than 125% of the actual amount; check the “estimates are used” box), and any transaction series totalling $50,000 or less “may be reported as ‘$50,000 or less’.”

Part V — Reportable transactions of a foreign-owned U.S. DE

This is the part built for you. The instructions: “You must check the box in Part V if you are a foreign-owned DE that had any other transaction … not already entered in Part IV. These transactions include amounts paid or received in connection with the formation, dissolution, acquisition, and disposition of the entity, including contributions to, and distributions from, the entity. Describe these on an attached statement.”

What a dormant LLC’s Part V statement typically contains, each in U.S. dollars:

• State formation fee paid by the owner on the LLC’s behalf (a contribution).
• Registered agent fee paid by the owner.
• Cash the owner deposited to open or fund the LLC’s bank account (a contribution).
• Any money the owner took out (a distribution).
• In the final year, dissolution costs and the final distribution.

Head the statement with the LLC’s name and EIN, the tax year, and “Form 5472, Part V.” Keep it to plain line items with amounts.

Part VI — Nonmonetary transactions

If you transferred property or services to the LLC for less than full value — for example, contributed a laptop or a domain name — check the box and attach a description with a reasonable estimate of value. Most simple LLCs leave this blank.

Part VII — Additional information (lines 37 to 43b)

“All reporting corporations must complete Part VII.” For a typical LLC:

• 37–38c (imports from a foreign related party): usually “No”, unless the LLC buys inventory from its owner’s company abroad — then “Yes” and answer 38a–38c.
• 39 (cost sharing arrangement): “No”.
• 40a (interest or royalty disallowed under section 267A): “No” for almost all small LLCs.
• 41a (FDII deduction): “No”.
• 42a–42b (loans at or outside the safe-haven interest rate): “No” unless there is an owner loan; if there is, answer based on the rate charged.
• 43a–43b. The instructions say “Do not complete these lines if the reporting corporation is a foreign-owned U.S. DE.” Leave blank.

Parts VIII and IX

Cost sharing arrangements and base erosion payments under section 59A. Not applicable to a single-owner LLC without intercompany intangible arrangements. Leave blank.

The pro forma Form 1120: what to write on the cover

Form 5472 has no signature line and cannot be filed alone. The instructions say a foreign-owned U.S. DE files “a pro forma Form 1120 … with Form 5472 attached,” and that “the only information required to be completed on Form 1120 is the name and address of the foreign-owned U.S. DE and items B and E on the first page.”

We cover the “why” — what pro forma means and why an LLC files a corporate form at all — in the pro forma Form 1120 guide. If you are wondering whether you need a real 1120 instead, see Form 1120 vs pro forma 1120.

Where to send it, and when

The instructions give a dedicated mailing address and say plainly: “These filers do not use the mailing address provided in the Instructions for Form 1120.”

• Fax (300 DPI or higher): 855-887-7737
• Mail: Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112 Attn: PIN Unit, Ogden, UT 84201

Electronic filing: “If you are a foreign-owned U.S. DE, you cannot file Form 5472 electronically.” Any software or service that claims to e-file this package for a disregarded LLC is describing something else. Faxing from abroad has its own quirks — how to fax Form 5472 to the IRS covers cover sheets and proof.

Deadline. Form 5472 is due with the pro forma 1120, and Form 1120 is due “by the 15th day of the 4th month after the end of its tax year” — April 15 for a calendar-year LLC. Form 7004 extends that to October 15. For a foreign-owned DE the 7004 has its own rules: enter form code 12 (Form 1120) on Part I line 1, write “Foreign-owned U.S. DE” across the top, and mail or fax it to the same Ogden address by the original due date. How Form 7004 works for a foreign-owned LLC has the walk-through.

Can you fill out Form 5472 yourself, for free?

Yes, legally and practically. The form and instructions are free on IRS.gov, there is no filing fee, and no rule requires a paid preparer. A careful owner with a dormant LLC, a calculator, and an afternoon can produce an acceptable package.

What actually goes wrong when people do — drawn from the returns we are asked to fix:

The stakes are asymmetric. “Filing a substantially incomplete Form 5472 constitutes a failure to file,” and the penalty for failure to file is $25,000 per form — plus $25,000 for each 30-day period the failure continues beyond 90 days after IRS notice. The Form 5472 penalty, explained goes through how it is assessed. If you have already missed a year, the past-due filing service brings it current with a reasonable cause statement; whether the IRS grants relief is their decision, not ours to promise.

A worked example: dormant Wyoming LLC, owner in the Philippines

Maria, a resident of Manila, formed a Wyoming LLC in March. She paid the $100 state fee and a $50 registered agent fee from her personal card, wired $500 into the LLC’s new U.S. account in June, and the LLC did nothing else. Her Form 5472 for that year:

• Part I: LLC name, U.S. address, EIN; 1c $500; 1f $650; 1g 1; 1j checked (first year); 1l United States; 1m the March formation date; 1o Philippines; lines 2 and 3 checked.
• Part II: Maria’s name and Manila address on 4a; 4b(1) blank; 4b(2) a reference ID such as MARIA001; 4b(3) her Philippine TIN; 4c–4e Philippines.
• Part III: “foreign person” checked; Maria again on 8a–8g; 8e “25% foreign shareholder”.
• Part IV: blank (no sales, rents, services, loans or interest).
• Part V: box checked; statement listing $150 formation costs paid on the LLC’s behalf and a $500 capital contribution, total $650.
• Part VI: blank. Part VII: 37, 39, 40a, 41a, 42a, 42b all “No”; 43 blank.
• Pro forma 1120: “Foreign-owned U.S. DE” across the top, name, address, item B EIN, item E “Initial return”, signed.

Faxed to 855-887-7737 before April 15 of the following year, with the fax confirmation kept.

If your facts are messier than Maria’s — an owner loan, payments for your own services, a foreign parent company — the form is the same but the entries multiply, and that is the point at which most owners hand it over. Our Form 5472 filing service prepares and signs the package as a professional U.S. tax preparer and files it by fax or mail, at a flat $349.

Official references: IRS — Instructions for Form 5472 (Rev. 12/2024) · IRS — About Form 5472 · IRS — Instructions for Form 1120 · Treas. Reg. §1.6038A-2 (reporting requirements) · Treas. Reg. §301.7701-2 (disregarded entities).

This article is general information, not tax or legal advice. Confirm the rules that apply to your specific situation before acting.