Form 5472 for Crypto Traders with US LLCs
Updated June 2026 · Reviewed by a Form 5472 specialist
Updated June 2026 · Reviewed by a Form 5472 specialist
The short answer
Key takeaways
If a non-US person owns at least 25% of a US LLC used to trade crypto, the LLC files Form 5472 whenever it has a reportable transaction. Because funding the LLC counts, virtually every foreign-owned crypto SMLLC must file — about 99% of them.
The trigger has two parts: a foreign person owns 25% or more of the US entity, and the entity had a reportable transaction with that owner or a related foreign party during the year. Crypto traders almost always satisfy both. The moment you wire dollars or send crypto from your personal wallet into the LLC's exchange or bank account, you have made a capital contribution — and that single transfer is a reportable transaction. See our deep dive on the foreign-owned single-member LLC rules.
The disregarded-entity-as-corporation rule has applied to foreign-owned single-member LLCs since tax years beginning on or after January 1, 2017 (final regulations T.D. 9796). It treats your LLC as a corporation only for this reporting purpose — you still owe no entity-level US tax on a disregarded entity that is not engaged in a US trade or business.
| Setup | Files Form 5472? | Filed with |
|---|---|---|
| Non-US owner, single-member crypto LLC | Yes — funding counts | Pro forma Form 1120 |
| Non-US owner, LLC taxed as C-corp | Yes — if 25%+ foreign | Form 1120 |
| Two non-US members, taxed as partnership | Generally no (Form 1065/K-1) | Form 1065 |
| US-citizen owner, no foreign owner | No | — |
Source: IRC §6038A; IRS Instructions for Form 5472. Verified June 2026.
Yes. Money or crypto you move between yourself and the LLC's exchange account is a reportable transaction. Contributions, loans, and distributions are all reported in US dollars on Part V. Even one transfer in the year triggers the filing.
This is where crypto traders trip up. They assume that because the LLC trades on-exchange and never pays the owner a salary, nothing is “reportable.” In fact, the very act of capitalizing the trading account is the reportable event. The four buckets to watch are below.
| Transfer | What it is | Form 5472 line |
|---|---|---|
| You send USDC into the LLC exchange wallet | Capital contribution | Part V — contributions |
| You lend the LLC funds to trade | Loan from related party | Part V — amounts loaned |
| LLC sends profits back to you | Distribution | Part V — distributions |
| You pay a formation/agent fee for the LLC | Capital contribution (paid-in) | Part V — contributions |
Source: IRS Instructions for Form 5472, Part V (foreign-owned U.S. DE). Verified June 2026.
Note what is not on this list: buying and selling crypto inside the exchange between unrelated parties is a market trade, not a related-party transaction, so it is not a Form 5472 line item. What matters for Form 5472 is the flow of value between you and your own LLC. The penalty for missing it is steep — see the Form 5472 penalty rules.
You convert each contribution, loan, or distribution to US dollars using a reasonable exchange rate at the time of the transfer, then report the totals on Part V. Form 5472 is reported entirely in USD — never in coins or tokens.
Form 5472 has no field for BTC, ETH, or USDC quantities. Each transfer is translated into a single US-dollar figure. The cleanest method is to record the USD value at the timestamp the asset entered or left the LLC's account, using the exchange's own price feed or a recognized index price. Keep a simple ledger: date, asset, quantity, USD value, and which bucket (contribution, loan, distribution).
Pull a CSV of deposits and withdrawals from each exchange, mark which counterparty was you (the owner) versus the open market, then sum the owner-side flows by category. The market trades net out for income-tax purposes; the owner-side flows are what populate Part V. If you also have US-source income, separate compliance may apply — read Form 5472 for digital nomads for how location and source rules interact.
A foreign-owned single-member LLC cannot e-file. You attach Form 5472 to a pro forma Form 1120and mail it to P.O. Box 149342, Austin, TX 78714-9342, or fax it to 855-887-7737. Keep proof of the two accepted methods.
There is no electronic path for a foreign-owned disregarded entity. The IRS accepts exactly two delivery methods, and you should keep the receipt or fax confirmation as your proof of timely filing. The pro forma 1120 carries only top-line identifying information — name, EIN, address — and the real disclosure lives on the attached 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.
If you would rather not handle mailing logistics from overseas, our filing service prepares and files the whole package for you.
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 filing deadline to October 15, 2026 — a 6-month extension.
The deadline is the 15th day of the 4th month after the tax year ends, which is April 15 for a calendar-year LLC. The Form 7004 extension only moves the filing date; a disregarded entity has no entity-level tax to pay, so there is nothing to remit. The extension does not erase any reportable transaction or reduce the penalty exposure if you ultimately miss the extended date.
The penalty is $25,000 per form, per year, per entity under IRC §6038A(d) — with no cap and no statute of limitations (IRC §6501(c)(8)). An additional $25,000 accrues every 30 daysafter a 90-day IRS notice.
This is one of the harshest information-return penalties in the tax code, and it applies to honest mistakes and missed deadlines exactly the same as to willful non-filing. Because there is no statute of limitations on an unfiled information return, a crypto LLC that never filed three years ago can still be assessed $25,000 for each of those years today.
| Trigger | Penalty |
|---|---|
| Failure to file or maintain records | $25,000 per form, per year |
| Continued failure 90 days after IRS notice | +$25,000 for each 30-day period |
| Number of unfiled years | Multiplies — no cap, no statute of limitations |
Source: IRC §6038A(d); §6501(c)(8). Verified June 2026.
Two unfiled years on a single crypto LLC is already $50,000 of exposure before any 30-day additions. Read the full rule on the penalty page.
No. Under FinCEN's March 2025 interim final rule, US-formed entities — including foreign-owned US LLCs — are exempt from beneficial ownership (BOI) reporting. Only foreign reporting companiesfile. Form 5472 is separate and still required.
Many crypto founders conflate the two obligations. They are entirely different regimes. The Corporate Transparency Act's BOI report goes to FinCEN, while Form 5472 goes to the IRS with your pro forma 1120. Per FinCEN's March 2025 interim final rule, a US-formed LLC — even one owned by a non-US person — is now exempt from BOI reporting; only entities formed abroad and registered to do business in a US state file BOI.
That exemption changes nothing about Form 5472. Your foreign owned LLC taxes obligation to file Form 5472 with a pro forma 1120 stands every year you have a reportable transaction. If you came through a formation platform, see Stripe Atlas founders: your Form 5472 obligation.
The IRS charges nothing, but one mistake costs $25,000. Specialist services range from $299 (form5472.tax) to $547 (form5472.online) to $1,999/year (doola) for the same Form 5472 plus pro forma 1120.
DIY is free but unforgiving — the $25,000 penalty applies to a single missed deadline or a misvalued transfer. For a flat $299, form5472.tax prepares Form 5472 and the pro forma Form 1120, reviews your exchange transfers, and files the package correctly, saving $248versus form5472.online and far more versus doola's $1,999/year or Firstbase's $999–$1,499/year. Compare on the pricing page or start on the apply page.
Form 5472 and pro forma 1120, with your exchange transfers reviewed and filed for a flat $299. Or message us first — we answer every question.