Form 5472 vs Form 5471: Full Comparison With Decision Tree

Both forms exist so the IRS can see ownership and money crossing the US border, but they look in opposite directions. Form 5472 looks inward: a foreign person owns a US company, and the IRS wants to see the transactions between them under IRC §6038A. Form 5471 looks outward: a US person owns a foreign corporation, and the IRS wants visibility into that offshore entity under IRC §6038 and §6046.

If you only own a foreign-owned US LLC, you are squarely in Form 5472 territory — see what is Form 5472 for the full definition.

The most common Form 5472 filer is a foreign-owned single-member LLC used for e-commerce, consulting, or SaaS. Because forming and funding an LLC always moves money from the owner, virtually every foreign-owned SMLLC has a reportable transaction — funding the LLC counts — so almost all of them must file. Form 5471, by contrast, is for US persons with offshore companies and is split into five filing categories based on control percentage and the type of transaction.

Not sure Form 5472 applies to your LLC? Read the 5472 vs 5471 reference page for the detailed ownership tests.

This is the single biggest practical difference. A disregarded LLC has no income tax return of its own, so it uses a pro forma 1120 purely as an envelope to carry Form 5472 to the IRS. The 1120 shows only the entity's identifying details — there is no tax calculation. Learn why on our pro forma 1120 explainer.

Form 5471 has no separate cover form. The US owner already files an income tax return, and Form 5471 rides along as an attachment to it. That is why Form 5471 normally e-files with the return while a disregarded entity's Form 5472 cannot — a difference covered in detail on our disregarded entity guide.

Why a disregarded entity matters here

Since 2017, under T.D. 9796, a foreign-owned single-member LLC is treated as a corporation for Form 5472 reporting purposes only. It keeps disregarded-entity treatment for everything else, which is exactly why it borrows the 1120 cover rather than filing a true corporate return.

For a calendar-year filer, both forms share the same headline date: the deadline for the 2025 tax year is April 15, 2026. Form 5472 follows the 1120 calendar, while Form 5471 follows whatever return it is attached to. The six-month extension to October 15, 2026 is automatic for Form 5472 if you file Form 7004 on time — see the Form 5472 overview for the mechanics.

There is no e-file path for a foreign-owned disregarded entity. The pro forma 1120 with Form 5472 attached has only two accepted delivery methods, and you must keep proof of filing. The full walkthrough is in our disregarded entity explainer.

Each Form 5472 filing also needs a stable identifier — see our reference ID number guide to set one up correctly.

These are among the harshest information-return penalties in the tax code. For Form 5472, the penalty sits in IRC §6038A(d), and because there is no statute of limitations on an unfiled information return under IRC §6501(c)(8), a year missed long ago can still be assessed today. Form 5471 carries a parallel $25,000 penalty under IRC §6038(b), plus a possible 10% reduction in foreign tax credits.

We prepare and file Form 5472 correctly so the penalty never applies, but we do not offer penalty-abatement or IRS representation — that is a separate credentialed service. Compare the cost of doing it right on the pricing page.

People often bundle these three filings together, but they are governed by different agencies. BOI (beneficial ownership information) goes to FinCEN, while Form 5472 and Form 5471 go to the IRS. Under the March 2025 interim final rule, a US-formed entity such as a foreign-owned US LLC does not file BOI at all; the obligation now falls only on foreign reporting companies registered to do business in the US.

So if you own a foreign-owned US LLC, your real annual obligation is Form 5472 with the pro forma 1120 — not BOI, and not Form 5471. Start that filing on the apply page.

Use this decision tree top to bottom and stop at the first match. It resolves the vast majority of cases in under a minute.

The decision tree

1. Are you a non-US person who owns at least 25% of a US LLC or corporation? If yes, and the entity had any reportable transaction (funding the LLC counts), you file Form 5472. A foreign-owned single-member LLC attaches it to a pro forma Form 1120 and mails or faxes it.

2. Are you a US person who owns 10% or more of, or controls, a foreign corporation? If yes, you file Form 5471 with your US income tax return.

3. Are both true at once? Then you may owe both forms — each is judged separately, and each missed form is its own $25,000 penalty.

4. Neither true? A US-owned US LLC with no foreign owner generally files neither form.

If you landed on Form 5472, you are in the right place — the 5472 vs 5471 reference goes deeper, and the apply page starts your filing.