Form 5472 Parts I Through IX: What Each Section Requires

The current form (Rev. December 2025) is two pages and divided into nine numbered parts. The structure moves from who the parties are, to what moved between them, to advanced base-erosion disclosures that most filers never touch. Understanding which parts apply to you is the single biggest time-saver. The official line numbering is mirrored on the Form 5472 instructions page, and a filled-in sample is on the Form 5472 example page.

Part I has roughly a dozen lines (1a–1q). For a foreign-owned single-member LLC, the name on line 1a is the LLC's legal name, line 1b is its US mailing address, and line 1c is the EIN — not the owner's foreign tax ID. Line 1g asks for total assets, which for a small SMLLC is usually a small or zero figure. Lines on principal business activity and the 6-digit NAICS code describe what the business does (for example, 454110 for electronic shopping).

The line that trips people up

Line 1l asks for the total number of Forms 5472 filed — for most single-owner LLCs this is simply 1. Line 1m asks the total value of gross payments reported on all the forms. Getting Part I right is mostly about using the LLC's own details, not the owner's. See the worked sample on the Form 5472 example page.

Part II is split into a direct 25% foreign shareholder section and an ultimate indirect 25% foreign shareholder section. For a straightforward foreign-owned SMLLC, the same person appears as both the direct and ultimate owner. You report the owner's foreign address, country, and a foreign tax identification number if one exists — there is no requirement to obtain a US SSN or ITIN solely to complete this part.

A related party is any 25% foreign shareholder, any person related to the LLC or to that shareholder under IRC §§267(b), 707(b)(1), or 482, or any other party the entity transacted with that meets the related test. Part III collects that party's name, address, country, and tax IDs — the same fields as Part II but for the specific counterparty. A separate Form 5472 is filed for each related party, so an LLC that transacted with two related foreign parties files two forms.

For most single-owner e-commerce or consulting LLCs, the owner is the only related party, so Part III mirrors Part II. The Form 5472 instructions page details the related-party tests line by line.

Part IV is the standard transaction grid used by foreign-owned corporations. It lists categories such as sales of inventory, platform fees, rents paid, royalties, interest, and consideration for services, with a column for amounts paid by the reporting entity and amounts received. A foreign-owned single-member LLC generally does not use Part IV — its disregarded-entity transactions go in Part V instead. Part IV is relevant mainly when the entity is a C-corporation filing a real Form 1120.

Why SMLLCs usually skip Part IV

The 2017 regulations under T.D. 9796 created a separate reporting track for disregarded entities. That track is Part V, which captures contributions and distributions that Part IV's sales-and-services categories were never designed to hold.

Part V is the most important part for a foreign-owned single-member LLC, and the one that exists because of the 2017 disregarded-entity rule. Instead of the detailed sales grid in Part IV, Part V asks you to describe each reportable transaction in plain terms and attach a statement if needed. Common entries are the owner's initial capital contribution to fund the LLC, any owner loan to the company, and any distribution back to the owner.

Because forming and funding an LLC always moves money from the owner, virtually every foreign-owned SMLLC has a reportable transaction in Part V in its first year, so almost all of them must file. There is no de minimis amount: a $1 capital contribution is still a reportable transaction. A filled-in Part V is shown on the Form 5472 example page.

Part VI is a catch-all for reportable transactions that do not fit the earlier grids — for example, certain nonmonetary exchanges or transactions whose amounts cannot be determined. Most small LLCs leave it blank. Parts VII through IX implement the base erosion and anti-abuse tax (BEAT) and cost-sharing disclosures from the 2017 tax law. They apply only to applicable taxpayers — large corporations meeting the $500-million gross-receipts test — and ask about base-erosion payments and tax benefits.

For a foreign-owned single-member LLC, Parts VI through IX are almost always left blank. Filling them in when they do not apply is a common DIY error, but leaving a part blank that should be completed is the more dangerous mistake, because an incomplete form is treated as not filed.

The penalty does not require willful neglect — an honest blank on Part II or a misstated Part V amount can trigger the full $25,000 because the form no longer counts as filed. Under IRC §6501(c)(8), the IRS assessment window stays open until a complete Form 5472 is filed, which is why a year missed long ago can still be assessed today. The cleanest way to avoid all of this is to have every part reviewed before mailing.

For a flat $299, form5472.tax prepares all required parts, attaches the pro forma Form 1120, and files by mail or fax — far less than the $547 charged at form5472.online or the $1,999/year doola charges. Compare on the pricing page or start on the apply page.