Form 5472 & Foreign-Owned LLCs

How to File Form 5472: Step-by-Step Guide for Foreign-Owned LLCs (2025-2026)

10 min readQ&A Guide

Key Takeaways

  • You need your LLC's EIN, formation details, owner information, and transaction records before starting
  • Part I identifies the LLC; Part II identifies the foreign owner; Part III identifies the related party
  • Part IV reports monetary transactions; Part V reports contributions and distributions for DEs
  • Part IV must be completed when the related party is a foreign person — enter '0' on lines where no transaction occurred to show the section is complete
  • File by mail to the Ogden, UT address or by fax at 855-887-7737 — no electronic filing
  • Write "Foreign-owned U.S. DE" across the top of the pro forma Form 1120

What do I need before I start filling out Form 5472?

Before completing Form 5472, gather the following information:

Your LLC's EIN (Employer Identification Number) — You must have an EIN to file. If you do not have one, apply using Form SS-4.

Your LLC's formation details — State of formation, date of formation, and principal business activity.

Foreign owner information — Full legal name, address, country of citizenship/incorporation, and taxpayer identification numbers (U.S. TIN if any, foreign TIN if available).

Transaction records — Complete records of all money movements between you and the LLC during the tax year: capital contributions, distributions, loans, payments for services, rent, and any other transfers.

Exchange rate documentation — If transactions occurred in a foreign currency, records of the exchange rates used for conversion to U.S. dollars.

How do I complete Part I (Reporting Corporation)?

Part I identifies the reporting corporation — your LLC.

Line 1a: Enter the LLC's full legal name and address. Include suite or room numbers. For foreign addresses, use the format: city, province/state, country (no abbreviations).

Line 1b: Enter the LLC's EIN.

Line 1c: Enter total assets. For a pro forma filing, this is typically the total value of assets held by the LLC (bank account balance, equipment, etc.).

Lines 1d-1e: Describe the principal business activity and enter the corresponding 6-digit NAICS code from the Form 1120 instructions. Common codes for foreign-owned LLCs include: 541511 (Custom Computer Programming Services) for indie developers and SaaS builders, 454110 (Electronic Shopping) for e-commerce and dropshipping, 541611 (Management Consulting) for consultants, and 511210 (Software Publishers) for app store publishers. Choose the code that best matches your LLC's primary revenue source.

Line 1f: Enter the total value (in USD) of all foreign related party transactions reported in Parts IV and VI (and Part V if applicable).

Line 1g: Enter the total number of Forms 5472 being filed — usually "1" if you have only one foreign owner.

Line 1j: Check the box if this is the first year you are filing Form 5472.

Line 1l: Enter the country of incorporation — this is "United States" for a U.S. LLC.

Line 1n: Enter the countries under whose laws the reporting corporation files an income tax return as a resident. For a foreign-owned single-member LLC (disregarded entity), enter "United States." Although the LLC is disregarded for income tax purposes, the IRS treats it as a domestic corporation for Form 5472 reporting. The pro forma Form 1120 is filed with the IRS (a U.S. tax authority), and the form's instructions do not carve out an exception for disregarded entities on this line. Do not enter the foreign owner's country here — that would describe where the owner files, not where the LLC files. Do not leave it blank or enter "None" — the IRS may treat an incomplete Part I as a substantially incomplete filing, which carries the same $25,000 penalty as failure to file.

Line 1o: Enter the principal countries where the LLC conducts business. Do not enter "worldwide."

Line 3: Check the box indicating the filer is a foreign-owned U.S. disregarded entity.

How do I complete Part II (25% Foreign Shareholder)?

Part II identifies the foreign owner(s). For a single-member LLC, you have one 100% owner.

Lines 4a-4e: Enter the largest direct 25% foreign shareholder's information — this is you (the owner). Include your full name, address, country of citizenship or incorporation, and ownership percentage (100% for a single-member LLC).

Line 4b(1): If you have a U.S. identifying number (SSN, ITIN, or EIN), enter it here.

Line 4b(2): If you do not have a U.S. identifying number, enter a Reference ID Number. This is an alphanumeric identifier (up to 50 characters, no special characters or spaces) that you assign and use consistently year after year.

Line 4b(3): Enter your foreign taxpayer identification number (FTIN) if you have one. Enter "None" or "N/A" if not available.

Lines 5-7: These lines are for additional shareholders. For a single-member LLC, they are typically left blank.

If the direct owner is a foreign company that is itself owned by another foreign person, you may need to report the ultimate indirect shareholder on lines 6-7.

How do I complete Part III (Related Party)?

Part III identifies the related party with whom reportable transactions occurred. For most foreign-owned single-member LLCs, the related party is the same person as the 25% foreign shareholder in Part II — the foreign owner.

Line 8a: Enter the related party's name and address.

Line 8b(1): Enter the related party's U.S. identifying number (if any).

Line 8b(2): If the related party is foreign with no U.S. identifying number, enter the Reference ID Number (same rules as Part II).

Line 8c: Check whether the related party is a foreign person.

Line 8d: Describe the principal business activity of the related party.

Line 8e: Check the applicable box for the relationship. The three options are: 'Related to reporting corporation,' 'Related to 25% foreign shareholder,' and '25% foreign shareholder.' For a foreign-owned single-member LLC where the related party is the foreign owner, check '25% foreign shareholder' — the owner holds 100% ownership, which exceeds the 25% threshold.

How do I complete Part IV (Monetary Transactions)?

Part IV reports all monetary transactions between the LLC and the foreign related party. Remember: only complete this section for foreign related parties (not domestic).

Amounts received by the reporting corporation (lines 7-21): Report amounts the LLC received from the foreign owner. Common entries include capital contributions, loans from the owner, and payments for services.

Amounts paid by the reporting corporation (lines 22-35): Report amounts the LLC paid to the foreign owner. Common entries include distributions, loan repayments, interest payments, and management fees.

For loan amounts (lines 17 and 31), you can choose between the outstanding balance method (report beginning and ending balances) or the monthly average method (skip beginning balance, report only the monthly average on the "b" line).

All amounts must be in U.S. dollars. Use the accrual method — report amounts when earned or owed, not when cash changes hands.

Important: The form states that Part IV 'must be completed' when the foreign person box is checked in Part III. For transaction lines where no transaction occurred, you may enter '0' to show you reviewed the line and confirmed no activity — this demonstrates the section is fully completed as required. If estimates are used for any amounts, check the estimates box in the Part IV heading.

How do I complete Part V (Foreign-Owned U.S. DE Transactions)?

Part V is specifically for foreign-owned U.S. disregarded entities. This is where you report transactions unique to your entity type:

Check the appropriate boxes for the types of transactions that occurred: formation, dissolution, acquisition, disposition, contributions to the entity, or distributions from the entity.

If you check "contributions" — this covers any money you put into the LLC during the year (capital contributions, paying LLC expenses out of personal funds).

If you check "distributions" — this covers any money the LLC paid to you.

If the LLC had other transactions not covered by Part IV (as defined under Regulations 1.482-1(i)(7)), check the "other" box and attach a statement describing these transactions.

How do I complete Part VII (Additional Information)?

All reporting corporations must complete Part VII. For most foreign-owned single-member LLCs, most of Part VII will not apply, but you must still review each question.

Lines 40a-40b (Section 267A): These lines ask about interest or royalty deductions disallowed under Section 267A (hybrid arrangement rules). Most simple LLCs will answer "No" to 40a.

Lines 41a-41d (Section 250 FDII): These lines relate to the foreign-derived intangible income deduction. This generally applies only to C corporations, not disregarded entities.

Lines 42a-42b (Safe-haven interest rates): If the LLC has loans with the foreign owner, check whether the interest rate falls within the safe-haven range (100%-130% of the Applicable Federal Rate). If the LLC has no loans, these lines do not apply.

Lines 43a-43b (Section 385 covered debt): These lines apply only to domestic corporations (not foreign-owned U.S. disregarded entities), so they can be skipped.

Can I mix typed and handwritten entries on Form 5472?

Yes. The IRS accepts both typed and handwritten entries on paper tax forms, and you can mix both on the same form. This is extremely common — many CPAs print pre-filled forms and then handwrite corrections or additions by hand.

If your filing software fills in most fields but leaves one incomplete (for example, printing '202' instead of '2025' in the year field), you can simply complete it by hand with a pen. The IRS will read it normally.

Rules for handwritten entries:

Use black or blue ink — never pencil.

Write legibly — print rather than cursive if your handwriting is hard to read.

Stay within the designated fields — do not write in margins or between lines.

If you make an error, draw a single line through the incorrect entry, write the correct entry nearby, and initial the change. Do not use white-out.

The things that actually matter for IRS acceptance are: correct EIN, correct addresses, all required parts completed, signature present, and filed on time. A handwritten digit completing a partially-typed field is a complete non-issue.

Where do I mail the completed Form 5472?

Foreign-owned U.S. disregarded entities file Form 5472 (attached to the pro forma Form 1120) at a dedicated address:

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

By fax (at 300 DPI or higher resolution): 855-887-7737

Important: Foreign-owned U.S. disregarded entities cannot file Form 5472 electronically. You must use mail or fax.

25% foreign-owned U.S. corporations (not disregarded entities) attach Form 5472 to their regular Form 1120 and file at the standard address for their state.

form 5472foreign-owned LLCIRS reportingpro forma 1120$25000 penalty

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