Form 5472 Complete Guide 2026: Everything You Need to Know
Updated June 2026 · Reviewed by a Form 5472 specialist
Updated June 2026 · Reviewed by a Form 5472 specialist
The short answer
Key takeaways
Form 5472 is the IRS “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.” It exists under IRC §6038A so the IRS can see money moving between a US business and the foreign people who control it.
Form 5472 is not a tax-payment form — it is a disclosure. Congress created the requirement in Internal Revenue Code section 6038A to detect transfer-pricing abuse and income shifting by foreign owners of US companies. Final regulations under T.D. 9796 extended it to foreign-owned single-member LLCs for tax years beginning on or after January 1, 2017, treating those disregarded entities as corporations for this reporting purpose only.
The form lists who the foreign owner is, what the US entity is, and the dollar amount of every reportable transaction between them. There is no tax calculation on it. For the full definition, see what is Form 5472.
Any US corporation or LLC that is at least 25% owned by a non-US person and had at least one reportable transaction during the year must file. The most common filer is a foreign-owned single-member LLC used for e-commerce, consulting, or SaaS.
Two conditions must both be true: a foreign person owns at least 25% of the US entity, and the entity had a reportable transaction with that owner or another related foreign party. Because forming and funding an LLC always moves money from the owner, virtually every foreign-owned single-member LLC has a reportable transaction in its first year.
| Entity type | Files Form 5472? | Filed with |
|---|---|---|
| Foreign-owned single-member LLC | Yes — if reportable transaction | Pro forma Form 1120 |
| Foreign-owned US C-corporation (25%+) | Yes — if reportable transaction | Form 1120 |
| Multi-member LLC taxed as a partnership | Generally no (Form 1065/K-1) | Form 1065 |
| US-owned LLC, no foreign owner | No | — |
Source: IRC §6038A; IRS Instructions for Form 5472. Verified June 2026.
Not sure if it applies to you? The 60-second qualifier walks through it.
Form 5472 has nine parts. They identify the US reporting entity, the 25% foreign owner, related parties, and the dollar amount of every reportable transaction. A typical foreign-owned SMLLC completes only Parts I, II, III, V, and VI.
| Part | Reports |
|---|---|
| Part I | The US reporting LLC: name, EIN, business activity, total assets |
| Part II | The 25% foreign shareholder: name, country, tax ID |
| Part III | The related party the transactions were with |
| Part IV | Monetary transactions: services, rent, royalties, commissions |
| Part V | Reportable transactions of a foreign-owned U.S. disregarded entity |
| Part VI | Loans, contributions, distributions (nonmonetary/less common) |
| Parts VII–IX | Base erosion and cost sharing — large entities only |
Source: IRS Form 5472 (Rev. December 2025). Verified June 2026.
A line-by-line walkthrough is on the Form 5472 instructions page.
Form 5472 for the 2025 tax year is due April 15, 2026, filed with the pro forma Form 1120. Filing Form 7004 by April 15 extends the deadline to October 15, 2026.
A foreign-owned single-member LLC cannot e-file. The pro forma Form 1120 with Form 5472 attached must be mailed to P.O. Box 149342, Austin, TX 78714-9342, or faxed to 855-887-7737. Keep the receipt or fax confirmation as proof.
There is no e-file path for a foreign-owned disregarded entity. The only two accepted methods are mail and fax, and the filing must be sent by the deadline. The complete step-by-step is on how to file Form 5472.
| Method | Where | Proof to keep |
|---|---|---|
| P.O. Box 149342, Austin, TX 78714-9342 | Certified-mail receipt | |
| Fax | 855-887-7737 | Fax transmission confirmation |
Source: IRS Instructions for Form 5472 (foreign-owned U.S. DE). Verified June 2026.
The penalty is $25,000 per form, per year, per entity, under IRC §6038A(d). There is no cap and no statute of limitations, and an extra $25,000 accrues every 30 days after a 90-day IRS notice.
Form 5472 carries one of the harshest information-return penalties in the tax code. Because there is no statute of limitations on an unfiled information return, a year missed long ago can still be assessed today. Estimate your exposure with the penalty calculator, and read the full rule on the penalty page.
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