Form 5472 for foreign-owned LLCs: who files, what to report, how to send it

Since 2017, the IRS treats a single-member LLC owned by a foreign person as a corporation for one purpose only: Form 5472 reporting. The LLC still pays no corporate tax as a disregarded entity — but it must tell the IRS about money moving between it and its owner. The rule exists for transparency, and the penalty for ignoring it is severe.

Who must file

You must file if all of these are true:

• Your LLC was formed in the US.
• It has a single owner (or is otherwise disregarded for US tax).
• That owner is a foreign person (not a US citizen or resident).
• During the tax year, the LLC had at least one reportable transaction with a related party — which includes you.

Multi-member LLCs taxed as partnerships file different returns. C-corps owned 25% or more by foreign persons file Form 5472 with their real Form 1120.

What counts as a reportable transaction

Far more than most owners expect. For a foreign-owned disregarded entity, the IRS instructions include amounts paid or received in connection with the formation, dissolution, acquisition and disposition of the entity, including contributions to and distributions from it.

In plain terms:

• You paid the formation service or state fee for the LLC → reportable.
• You transferred money from your personal account to the LLC → reportable.
• You withdrew profit from the LLC → reportable.
• The LLC paid you, or you paid expenses on its behalf → reportable.

That is why “my LLC made no money, so I don’t need to file” is almost always wrong in the first year.

What you actually file

A foreign-owned disregarded entity files a package with three pieces:

1. A pro forma Form 1120: only the entity name, address, EIN, and items B and E on page 1 are completed. Write Foreign-owned U.S. DE across the top.
2. Form 5472: identifies the LLC, the foreign owner, and the dollar amounts of each reportable transaction.
3. Where required, a statement attached with additional information about ownership.

Most owners need a single Form 5472 per year. The return reports amounts; it does not compute tax.

Deadlines

Situation	Due date
Calendar-year LLC (the default)	April 15 of the following year
With an extension (Form 7004)	October 15

Filing Form 7004 by April 15 extends the deadline automatically. The first return is due the April after the LLC’s first (partial) year — an LLC formed in October 2026 files its first Form 5472 by April 15, 2027.

How to send it

You cannot e-file it. The pro forma 1120 with Form 5472 attached is faxed or mailed to the IRS. The mailing address the IRS lists for foreign-owned US disregarded entities is:

Internal Revenue Service, 1973 Rulon White Blvd., M/S 6112, Attn: PIN Unit, Ogden, UT 84201

The IRS also accepts these returns by fax at the number given in the current Form 5472 instructions. Because addresses and fax numbers change, confirm them in the IRS instructions every year, and keep proof of sending (a fax confirmation or tracked courier receipt).

The penalty

The penalty for failing to file a complete and timely Form 5472 is $25,000 per form, per year, with additional penalties if the failure continues after IRS notice. The IRS has applied it to small, revenue-free LLCs. Reasonable-cause relief exists but is not something to plan around.

DIY or hire someone?

The forms are short for a simple single-member LLC, and many owners file them themselves. Pay a preparer if you have several transaction types, inventory or US operations, or if you would rather not take the risk:

• Firstbase: $899/yr package for non-US single-member LLCs (Form 5472 + pro forma 1120).
• doola: filings included in the $1,999/yr Tax & Compliance plan.
• An independent US preparer experienced with foreign-owned LLCs: typically a few hundred dollars.

Whichever route you choose, Form 5472 does not replace your home-country tax return, where the LLC’s profit is often reportable.