What is Form 5472?

Published on January 23, 2026

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Form 5472: foreign-owned US LLC and corporation guide

Form 5472 is a US information return used to report transactions between certain US entities and their foreign owners or other foreign related parties.

Form 5472: what it is and who actually needs to file

Form 5472 is not a form where you calculate tax, instead, it is an information return the IRS uses to see what is going on between a US entity and its foreign owners or related parties.

You generally need Form 5472 if you have a 25 percent foreign-owned US corporation, a foreign corporation engaged in a US trade or business, or a foreign-owned US disregarded entity with reportable transactions.

The full name is long, but the idea is straightforward. Form 5472 tells the IRS:

Who the foreign owners and related parties are
What type of entity you have
What kinds of transactions happen between the US entity and those foreign parties

What exactly does Form 5472 report?

Form 5472 focuses on disclosure, not tax calculation. On the form, you typically report:

Details about the foreign owner and any other related foreign parties
Basic information about the US entity, such as whether it is a corporation or a disregarded entity
A list of reportable transactions between the US entity and its foreign owner or related parties

Reportable transactions can include things like:

Capital contributions
Loans in or out
Interest payments
Management or service fees
Purchases and sales of goods or property

Who actually needs to file Form 5472?

You are usually in Form 5472 territory if you have one of the following:

A US corporation that is at least 25 percent foreign-owned
A foreign corporation that is engaged in a US trade or business
A US disregarded entity (DE), such as a single-member LLC, that has a foreign owner and has reportable transactions with that owner or another related foreign party

Form 5472 applies when there is a meaningful level of foreign ownership and there are transactions between the US entity and that foreign owner or related parties.

For many US expats, the most common situation is a foreign-owned US LLC used for consulting, e-commerce, online services, or holding US assets. If that LLC is owned by a foreign person and treated as a disregarded entity, Form 5472 often becomes part of the annual compliance package.

What does “25% foreign-owned” actually mean?

For a US corporation, you are considered 25 percent foreign-owned if a foreign person owns, directly or indirectly:

At least 25 percent of the total voting power of all classes of voting stock, or
At least 25 percent of the total value of all classes of stock

The foreign person can be an individual, company, trust, or other non-US entity. If more than one foreign person is involved, things can become more technical, but the basic idea is that once foreign ownership reaches that level, the corporation may be required to file Form 5472.

How does this apply to foreign-owned US LLCs that are disregarded entities?

This is the part that surprises a lot of non-US owners. A single-member US LLC that is owned 100 percent by a foreign person is often treated as a disregarded entity for income tax purposes. That means its income is usually reported on the owner’s return, not on a separate US corporate return.

However, for Form 5472, the IRS treats that LLC as if it is a separate reporting entity. In that case:

The LLC typically files a pro forma Form 1120 (a mostly blank corporate return)
Form 5472 is attached to that pro forma return to report the required information

Even if there is no corporate tax to pay, the Form 5472 filing requirement can still exist.

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Which businesses trigger Form 5472 (foreign-owned US LLCs, corporations, and DEs)

The IRS is mainly interested in US entities that have meaningful foreign ownership and some kind of financial relationship with their foreign owners or related parties.

As a US expat, this often overlaps with the exact setup you might use for an online business, consulting work, or holding US assets, so it is worth getting clear on who is in the “danger zone” for Form 5472 and who is not.

Which types of businesses does Form 5472 actually apply to?

In broad terms, Form 5472 comes into play in three main situations:

25 percent foreign-owned US corporations
- A US corporation is considered “25 percent foreign-owned” when a foreign person owns, directly or indirectly:
  - At least 25 percent of the voting power, or
  - At least 25 percent of the total value of all classes of stock.
- If that test is met and there are reportable transactions with foreign related parties, the corporation is usually required to file Form 5472.
Foreign corporations engaged in a US trade or business
- A non-US corporation that is actively doing business in the US often has to file Form 5472 to report its dealings with US and foreign related parties.
- This could be a foreign company with a US branch, office, warehouse, or other regular activity in the US.
Foreign-owned US disregarded entities (DEs)
- A very common structure for non-US owners is a US single-member LLC that is 100 percent owned by a foreign person or foreign company.
- For income tax, that LLC may be treated as a disregarded entity, so its income is reported by the owner rather than on a separate corporate return.
- For Form 5472, however, that LLC is treated as a separate reporting entity if there are reportable transactions between the LLC and its foreign owner or other foreign related parties.
- In that case, the LLC usually files a pro forma Form 1120 with Form 5472 attached.

I am a US expat who owns a US LLC personally. Does that trigger Form 5472?

Not just because you live abroad. Form 5472 cares about whether the owner is foreign, not whether the owner lives outside the US.

If you are a US citizen who owns a US LLC directly, that LLC is not “foreign-owned” for Form 5472 purposes. Your expat status does not turn you into a foreign owner.
If your US LLC is owned by a foreign company or foreign individual instead, then it may be a foreign-owned disregarded entity, and Form 5472 can become relevant.

The important question is who legally owns the entity, not where you happen to live right now.

Does a business have to be large before Form 5472 applies?

No. The rules do not contain a size threshold that says small entities are exempt. Even a relatively small foreign-owned US LLC or corporation can be required to file Form 5472 if:

The foreign ownership test is met, and
There are reportable transactions with foreign related parties.

This is why many small online businesses and holding companies need to take Form 5472 seriously, even if their revenue is modest.

Form 5472 and reportable transactions: what the IRS expects you to disclose

Once you know your business is the kind of entity that can trigger Form 5472, the next step is understanding what goes on the form.

If you skip these or misunderstand them, the IRS will view the filing as incomplete, even if you submitted something on time.

What is a “reportable transaction” for Form 5472?

For Form 5472, a reportable transaction is any relevant transfer of money, property, or value between:

The reporting US entity, and
Its foreign owner, or
Other foreign related parties (for example, foreign parent companies, subsidiaries, or related individuals).

This includes both cash and certain non-cash transactions. It is not limited to big or unusual items. Everyday flows can count.

What are common examples of reportable transactions on Form 5472?

For a foreign-owned US LLC, corporation, or disregarded entity, typical reportable transactions might include:

Capital contributions
- The foreign owner sends money or property into the US entity as an injection of capital.
Distributions and withdrawals
- The US entity sends money or property back to the foreign owner, other than salary or routine reimbursements.
Loans and advances
- The foreign owner lends money to the US entity, or the entity lends money to the foreign owner.
- Repayments of those loans and any interest payments are also reportable.
Service and management fees
- The US entity pays a foreign related party for management, consulting, marketing, or other services.
- The reverse, where a foreign related party pays the US entity for services, can also be reportable.
Sales or purchases of goods or property
- The US entity buys inventory from a foreign parent company or sells goods to a related foreign company.
Royalties and licensing fees
- Payments for the use of intellectual property, such as trademarks, software, or patents, between the US entity and foreign related parties.

Do non-cash or “free” transfers count as reportable transactions?

In many cases, yes. Form 5472 is not limited to cash. It is about value moving across the relationship. Some examples:

A foreign owner contributes equipment or other assets to the US entity instead of cash.
The US entity provides services to a foreign related party without charging, even though it is giving up time or value.

If there is a transfer of something that has value, it may belong on Form 5472, even if no money is exchanged at that moment.

How much detail does the IRS want on Form 5472?

The IRS expects you to:

List each foreign related party that had reportable transactions with the US entity.
Classify the transactions into the categories used on Form 5472, such as loans, interest, service fees, sales, purchases, and so on.
Report the total amounts for each type of transaction during the year.

You do not itemize every invoice on the form, but you should have records that back up the totals. If the IRS asks questions later, you need to be able to show how you arrived at the numbers.

What if the amounts are small? Do I still need to report them?

Form 5472 does not include a built-in de minimis rule that says small amounts can be ignored. Even relatively small transfers can still be reportable if they fall into one of the categories.

For a small business, this is less about volume and more about awareness. If you have only a few transactions with a foreign owner, it may be very manageable to list them. The key is not to assume they are “too small to matter” and leave them off entirely.

Form 5472 deadlines, penalties, and how to fix a missed filing

Form 5472 is due on the same date as the entity’s Form 1120 or pro forma Form 1120 (April 15), including any valid extensions.

Once you know your business is caught by Form 5472, the next thing that really matters is timing. The IRS treats this form as a serious reporting requirement, even if your company is small or not making much money yet.

When is Form 5472 actually due?

Form 5472 is not filed on its own. It is attached to a tax return, usually one of these:

Form 1120 for a US corporation
A pro forma Form 1120 for a foreign-owned US disregarded entity, like a single-member LLC owned by a foreign person or company

For a calendar year entity, the usual pattern looks like this:

The due date is around April 15 of the following year, because that is when the Form 1120 is due.
If you file a valid extension for Form 1120, the due date for Form 5472 moves with it, usually to around October 15.

So if you have a foreign-owned US LLC with a 2025 calendar year, you would normally:

File the pro forma Form 1120 with Form 5472 by mid-April 2026, or
File an extension and then file both forms by mid-October 2026.

Your personal expat status does not change these entity deadlines. The automatic 2-month extension that expats get is for individual returns, not for corporate or pro forma 1120 filings.

What happens if I miss the Form 5472 deadline?

If you ignore an IRS notice and still do not fix the problem, additional penalties can pile up for the same year. The penalty can apply per entity, per year, which means it adds up quickly if you have multiple years of noncompliance.

Missing Form 5472 can also keep the statute of limitations open on the related return, giving the IRS more time to look at that year.

Can an “incomplete” Form 5472 really be treated like no filing?

Yes, it can. The IRS treats Form 5472 as not properly filed if, for example:

You leave out the foreign owner information
You do not list foreign-related parties
You skip reporting reportable transactions
You attach it to the wrong type of return or do not file the required pro forma Form 1120

In those situations, the IRS can say you failed to meet the Form 5472 requirement and apply the same penalties as if you never filed.