Form 5472 Line-by-Line Guide for Foreign-Owned US LLCs

If you are a non-US resident who owns a single-member US limited liability company (LLC), learning how to fill out Form 5472 and its companion return is an essential yearly chore. For US tax purposes, your LLC is classified as a foreign-owned domestic disregarded entity (foreign-owned U.S. DE), meaning the company does not pay corporate income tax by default, but it must report its ownership and cross-border transactions to the Internal Revenue Service (IRS).

To file correctly, you do not submit Form 5472 alone. You must attach it to a "pro forma" Form 1120 (U.S. Corporation Income Tax Return), writing "Foreign-owned U.S. DE" across the top, and deliver both documents together by fax or dedicated mail. Missing this requirement or submitting an incomplete form exposes the LLC to a $25,000 penalty for each failure.

In short:

• Foreign owners of single-member US LLCs must file Form 5472 with a pro forma Form 1120 for every year the LLC had a reportable transaction with them (money put in or taken out counts), even if the LLC had no revenue.
• The pro forma Form 1120 acts as a cover page: you only complete the LLC's name and address and items B (the EIN) and E on the first page.
• Reportable transactions on Form 5472 include contributions of capital, distributions, owner loans, reimbursements, and any operational fees between you and the company.
• The packet cannot be submitted through standard commercial e-file platforms; you must fax it to 855-887-7737 or mail it to the IRS PIN Unit in Ogden, Utah.
• The standard due date matches the federal corporate tax deadline (usually April 15), with a 6-month extension available via Form 7004.

Who needs this

Under Internal Revenue Code (IRC) Section 6038A, any domestic disregarded entity that is 100% owned (directly or indirectly) by a foreign person must file Form 5472 when it engages in reportable transactions.

You must file if:

• You are an individual who is not a US citizen or resident alien, or you are a foreign legal entity.
• You own 100% of a US LLC formed under state law (such as Delaware, Wyoming, or New Mexico).
• The LLC has not made an election on Form 8832 to be taxed as a corporation (it remains a disregarded entity).
• The company engaged in at least one reportable transaction during the calendar year (including formation expenses paid from personal funds, capital injections, withdrawals, or sales of goods and services with you or your foreign entities).

You do NOT need this specific filing if:

• Your LLC has two or more owners and is treated as a partnership (partnerships file Form 1065 instead).
• The LLC is 100% owned by a US citizen or permanent resident (green card holder).
• You elected to treat your LLC as a standard C corporation on Form 8832 (in which case you file a standard, full Form 1120 and attach Form 5472 under normal corporate rules).

What you need before you start

Gather the following items before drafting your forms:

• LLC Legal Documents: Your Articles of Organization and Certificate of Formation to confirm the legal name, state of registration, and formation date.
• LLC EIN Confirmation Letter (Form CP 575 or 147C): The official 9-digit US tax identification number issued to your LLC. No EIN yet? Without an SSN or ITIN you cannot use the online application; you apply with Form SS-4 (PDF) by fax or mail, and the SS-4 instructions say "only international applicants can receive an EIN by telephone." The fax numbers depend on where the business is located; take them from the current instructions.
• Foreign Tax Identification Number (FTIN): the tax identification number issued to you by your country of tax residence (for example the French "numéro fiscal").
• Accounting Ledger and Bank Statements: A record of every transaction between you (the owner) and the LLC during the tax year. This includes initial startup contributions, cash deposits, personal funds used to pay state fees or registered agent charges, and owner distributions.
• Principal Business Activity Code: A 6-digit NAICS code representing the LLC's core commercial operations (the list is in the Instructions for Form 1120).

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How to fill out Form 5472 and the pro forma Form 1120

A foreign-owned US disregarded entity cannot file Form 5472 as a standalone document. The IRS Instructions for Form 5472 specify that it must be filed as an attachment to a "pro forma" Form 1120. A pro forma return is a shell return used exclusively to carry information; you do not fill in income, deductions, or tax schedules on this Form 1120.

Download the official forms before you start:

Step 1: The Pro Forma Form 1120

Use the version of Form 1120 (PDF) matching the reporting year. At the very top of the page, above the form title, write or type in bold text: Foreign-owned U.S. DE.

Per the official instructions, you only complete the following identity items on the first page:

Leave Pages 2 through 6 of Form 1120 completely blank (including Schedule C, Schedule J, Schedule K, Schedule L, Schedule M-1, and Schedule M-2).

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Step 2: Form 5472 Walkthrough

Complete Form 5472 (PDF) (Rev. December 2023). The form asks you to "enter all information in English and money items in U.S. dollars."

Part I: Reporting Corporation

All reporting entities must complete Part I. For our purposes, the "reporting corporation" is your single-member LLC.

Leave lines 1i blank unless filing a corporate consolidated return.

Part II: 25% Foreign Shareholder

Report the foreign owner on lines 4a through 4e. Lines 5a to 5e are for a second direct 25% foreign owner, and lines 6a to 7e for the ultimate indirect owners (for example the people behind a foreign company that owns the LLC). If you own the LLC personally, leave lines 5a to 7e blank.

Part III: Related Party

Part III identifies the person or company on the other side of the reportable transactions. For a single-member LLC transacting directly with its founder, the related party is the founder herself.

Check the box indicating whether the related party is a foreign person or a U.S. person. For a foreign founder, check foreign person.

Part IV: Monetary Transactions Between Reporting Corporations and Foreign Related Party

Part IV is for money that moves between the LLC and you as part of the business itself: for example the LLC paying you a fee for services (line 29), buying stock from your foreign company (line 23), or lending you money (line 31). Sales to and purchases from unrelated customers or suppliers never go here.

Be careful with lines 21 ("Other amounts received") and 35 ("Other amounts paid"). The instructions say to include amounts there only "to the extent that these amounts are taken into account in determining the taxable income of the reporting corporation." Money you put into the LLC as capital, and money you take out as distributions, does not fit that description. Those go in Part V instead (see below).

Because you checked "foreign person" in Part III, the form asks you to complete Part IV. Enter the lines that apply to you. If none apply, lines 22 and 36 total zero.

Small amounts: if a type of transaction with the related party does not exceed $50,000 in total, the instructions allow you to report it as "$50,000 or less." Reasonable estimates (between 75% and 125% of the actual amount) are also allowed when exact figures cannot be determined; check the "estimates" box if you use them.

Part V: Reportable Transactions of a Foreign-Owned U.S. DE

This part exists only for foreign-owned disregarded LLCs, and for most founders it is the most important one. The instructions say you must check the box if the LLC "had any other transaction, as defined by Regulations section 1.482-1(i)(7) 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."

In practice:

• Check the box in Part V.
• Attach a statement titled for example "Form 5472, Part V, Reportable transactions of a foreign-owned U.S. DE", with the LLC's name and EIN. List each type of transaction with its total in US dollars for the year: capital you contributed, distributions you received, formation costs or state fees you paid personally for the LLC, expenses of the LLC you paid from your personal card.
• These amounts count in line 1f (see Part I).

Here is what Amélie's Part V statement can look like:

Part VI: Nonmonetary and Less-Than-Full Consideration Transactions

Complete this section only if you exchanged non-cash property, barter services, or digital assets with the LLC without full cash consideration. If none, leave the checkbox blank and proceed.

Part VII: Additional Information

All reporting corporations must answer the questions in Part VII:

• Line 37: Check No (unless you physically import commercial goods into the US from yourself or your foreign company).
• Line 38a–c: Leave blank if Line 37 is No.
• Line 39: Check No (cost sharing arrangements do not apply to standard freelance or SaaS LLCs).
• Line 40a: Check No (disallowed interest/royalty deductions under Section 267A).
• Line 41a: Check No (unless making an explicit Section 250 FDII claim).
• Line 42a & 42b: these questions are about loans between the LLC and you (or another related party) and the interest rate used. With no loan, check No to both. If you lent money to the LLC or borrowed from it, even without interest, read the instructions for lines 42a and 42b with your preparer before answering.
• Line 43a & 43b: Do not complete. The instructions specifically instruct: "Do not complete these lines if the reporting corporation is a foreign-owned U.S. DE."

Parts VIII and IX

• Part VIII (Cost Sharing Arrangement): Leave blank.
• Part IX (Base Erosion Payments, Section 59A): these lines concern the base erosion rules that target large corporations. For a typical founder LLC they are left blank; check the instructions if the LLC makes large deductible payments to foreign related parties.

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Worked example

To see how these rules apply in practice, let us examine a typical founder scenario.

Amélie Martin is a French tax resident living in Paris. On March 15, 2025, she formed Meridian Cloud Solutions LLC, a Delaware single-member LLC providing cloud software architecture consulting.

During 2025, her cash flows were as follows:

• Formation & Setup: Amélie deposited $5,000 from her personal French account into the LLC's US business bank account as startup capital.
• Commercial Revenues: The LLC received $50,000 from corporate clients in the UK and Germany. Because these transactions were with unrelated third parties, they are not reported on Form 5472.
• Operating Expenses: The LLC paid $3,000 to third-party software vendors (AWS, Stripe). These third-party costs are not reported on Form 5472.
• Owner Distributions: Amélie transferred $17,000 from the LLC bank account to her personal account in France as profit distributions.

How the numbers flow to the forms:

1. Pro Forma Form 1120:

   • Amélie writes "Foreign-owned U.S. DE" at the top.
   • She enters "Meridian Cloud Solutions LLC", the Delaware address, and EIN 12-3456789.
   • Box E(1) is checked for an initial return.
   • Income and deduction lines 1 through 37 remain completely blank.
   • She signs the bottom as "Sole Member".

2. Form 5472:

   • Part I, Line 1c (Total assets): $35,000 (the cash left in the LLC bank account on December 31: $5,000 + $50,000 − $3,000 − $17,000).
   • Part I, Line 1f & 1h (Total gross payments): $22,000 (the Part V transactions: $5,000 capital contribution + $17,000 distribution).
   • Part I, Line 1j: Checked (first year the LLC files Form 5472).
   • Part I, Lines 2 and 3: Checked (foreign owner of at least 50%, and foreign-owned U.S. DE).
   • Part II & III: Amélie lists herself, her French address and her French FTIN (she has no ITIN). She also chooses to add the reference ID AMARTIN01 and will reuse it every year.
   • Part IV: no business transactions with Amélie (she did not invoice the LLC, borrow from it or sell it anything), so lines 22 and 36 total zero.
   • Part V: Checked, with an attached statement detailing the $5,000 contribution and $17,000 distribution.
   • Part VII: Lines 37, 39, 40a, 41a, and 42 checked "No". Lines 43a–43b left completely blank.

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How and where to file

Foreign-owned US disregarded entities cannot file Form 5472 electronically through regular tax software. You must submit your packet by fax or mail using the dedicated IRS intake unit.

Dedicated Filing Methods

Assemble your packet in this order:

1. Pro forma Form 1120 (with "Foreign-owned U.S. DE" written at the top and signed).
2. Form 5472.
3. Attached statements (such as the Part V explanation).

Submit via one of the two official channels:

• By fax: Fax your complete document package to: 855-887-7737 (transmission resolution must be 300 DPI or higher).
• By Mail: Send via postal service or courier to: Internal Revenue Service 1973 Rulon White Blvd M/S 6112 Attn: PIN Unit Ogden, UT 84201

Do not use the general corporate filing addresses listed in the Form 1120 instructions.

Deadlines and Extensions

• Standard Deadline: Form 5472 follows the federal corporate income tax deadline, which is generally April 15 following the close of the calendar tax year.
• Requesting an Extension: You can obtain an automatic 6-month extension by filing Form 7004 (PDF).
  • On Form 7004, Part I, Line 1, enter Form Code 12 (the code for Form 1120).
  • Write "Foreign-owned U.S. DE" across the top of Form 7004.
  • Enter -0- on lines 6, 7, and 8.
  • You must fax or mail Form 7004 to the same Ogden, UT fax number or address shown above by the regular due date.
  • An extension moves your filing deadline to October 15.

Records you must keep

The instructions say a reporting corporation "must keep the permanent books of account or records as required by section 6001", sufficient to establish the correct treatment of transactions with related parties. The IRS manual adds that these records generally must be kept in the United States; records kept abroad are acceptable if they are produced (or brought to the US) within 60 days of an IRS request. A missing-records failure carries the same $25,000 penalty as a missing form.

Proof of Filing

Keep your own proof of filing, permanently:

• A complete PDF copy of the exact package sent.
• The transmission confirmation sheet generated by your fax service showing date, time, and successful delivery.
• If mailed, registered mail or courier delivery tracking receipts confirming arrival at the Ogden PIN Unit.

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Common mistakes to avoid

• Filing Form 5472 alone: for a foreign-owned LLC, Form 5472 must be attached to a pro forma Form 1120. A penalty applies when the form is not filed "in the manner prescribed".
• Filling in the income lines of Form 1120: the instructions only ask for the name, address and items B and E. Entering revenue or deductions turns a pro forma return into something that looks like a real corporate return and invites confusing IRS letters.
• Reporting third-party customer sales in Part IV: lines 9 through 36 are only for transactions between the LLC and the foreign related party (you). Customer revenue does not belong here.
• Putting contributions and distributions on lines 21 and 35: those lines are limited to amounts that affect the LLC's taxable income. Capital in and out goes in Part V, with an attached statement.
• Skipping years with no revenue: if money moved between you and the LLC (capital you put in, money you took out, LLC fees you paid personally), Form 5472 is required even if the LLC had no sales.
• Mailing to the standard Form 1120 address: the instructions say foreign-owned U.S. DEs "do not use the mailing address provided in the Instructions for Form 1120". Use the fax number or the Ogden PIN Unit address.
• Forgetting to check Part I, Line 3: this box tells the IRS the return comes from a foreign-owned disregarded LLC. Leaving it blank makes the filing harder to process correctly.
• Leaving the FTIN box empty: a foreign-owned LLC must enter the owner's FTIN on 4b(3), or "None"/"N/A" if there is none. Use the same identifiers every year.

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Your checklist

1. Obtain your LLC's legal documents and verify the official EIN issued by the IRS.
2. Calculate all cash movements between your personal accounts and the LLC bank account during the tax year.
3. Download the current official versions of Form 1120 and Form 5472.
4. Prepare the pro forma Form 1120: enter name, address, EIN, check Box E, and write "Foreign-owned U.S. DE" across the top.
5. Sign and date page 1 of Form 1120. Leave all financial schedules blank.
6. Complete Form 5472: fill Parts I, II, III, IV, V, and VII.
7. Prepare a brief statement for Part V detailing owner contributions and distributions.
8. If extra time is required, file Form 7004 before the April deadline to extend to October.
9. Fax the combined packet to the IRS PIN Unit at 855-887-7737.
10. Archive the complete signed packet along with the successful fax transmission confirmation sheet.

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Official resources

• Form 5472 (PDF): The official information return for foreign-owned entities.
• Instructions for Form 5472 (PDF): Detailed line-by-line rules, definitions, and filing requirements.
• About Form 5472: IRS landing page with updates and revisions.
• Form 1120 (PDF): The corporate income tax return used as the required pro forma cover return.
• Form 7004 (PDF): The application for an automatic 6-month filing extension.
• Instructions for Form 7004 (PDF): Rules and procedures for requesting a business filing extension.
• Form SS-4 (PDF): Application for an Employer Identification Number.
• Apply for an EIN: Official IRS overview of the EIN application process.

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Frequently asked questions

What is the penalty for filing Form 5472 late?

A $25,000 penalty is assessed for failing to file Form 5472 when due and in the manner prescribed. Filing a substantially incomplete Form 5472 counts as a failure to file. If the IRS issues a failure notice and the return is not submitted within 90 days, an additional $25,000 penalty applies, for each related party, for every 30-day period (or part of one) the failure continues.

Can I file Form 5472 electronically?

No. Foreign-owned U.S. disregarded entities cannot use standard electronic filing methods. You must submit your pro forma Form 1120 and Form 5472 by fax or mail directly to the IRS Ogden PIN Unit.

Do I have to file if my LLC had no transactions at all?

If the LLC had zero financial activity, no bank accounts opened, no capital contributions, no startup expenses paid by the owner, and no fees paid, there are technically no reportable transactions under Regulations Section 1.482-1(i)(7). The instructions confirm that a foreign-owned LLC with no reportable transactions of the types in Parts IV, V and VI does not have to file. In practice, most founders do have at least one: the money used to form or fund the LLC, or LLC fees paid from a personal account. Check each year carefully before deciding not to file.

Does filing Form 5472 mean my LLC has to pay US income tax?

No. Form 5472 and the pro forma Form 1120 are strictly informational filings under Section 6038A. A disregarded entity owned by a nonresident is not subject to US corporate income tax simply because it files these forms. Whether you owe personal US income tax depends on whether your activities generate income effectively connected with a US trade or business (see our guide on the 1040-NR).

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Filing US tax paperwork from abroad can feel daunting, but once you break down each form into concrete steps, the process is straightforward. If you want professional assistance preparing your annual reporting, explore our Form 5472 + Pro Forma 1120 service or request a free preliminary check to confirm your filing obligations.