Form 5472 for UK LLC Owners: US-UK Filing Guide
Updated July 2026 · Reviewed by a Form 5472 specialist
Updated July 2026 · Reviewed by a Form 5472 specialist
The short answer
Key takeaways
Yes. A US LLC that is at least 25% UK-owned and had a reportable transaction must file Form 5472 with a pro forma Form 1120 by April 15. Because funding the LLC is reportable, virtually every UK-owned single-member LLC must file.
British founders form US LLCs to bill American clients in dollars, run SaaS on Stripe, or sell into the US on Amazon — usually through Stripe Atlas, doola, or a direct Wyoming or Delaware filing. The part nobody advertises is what happens next: once a non-US person owns at least 25% of a US entity, IRC section 6038A applies and Form 5472 becomes an annual obligation.
A single-member LLC owned 100% by one UK person is the standard case. The IRS disregards it for income tax, but since T.D. 9796 (tax years beginning on or after January 1, 2017) it is treated as a corporation solely for §6038A reporting. A UK founder with no US tax to pay still has a US form to file. The foreign-owned disregarded entity guide explains the entity, and the do-I-need-to-file qualifier confirms your position in a minute.
The 2001 US-UK Convention can eliminate US income tax: Article 7 exempts business profits with no US permanent establishment, Article 11 sets interest withholding at 0%, Article 12 sets royalties at 0%, and Article 10 caps dividends at 15% (5% for 10%+ corporate owners). But Form 5472 is an information return — no treaty article touches it.
The UK has a comprehensive treaty with the US, and it is worth knowing precisely what it does for a UK LLC owner:
| Treaty article | What it covers | Effect |
|---|---|---|
| Article 7 — Business Profits | Active business income | No US tax without a US permanent establishment |
| Article 10 — Dividends | US-source dividends | 15% withholding (5% if 10%+ corporate owner) |
| Article 11 — Interest | US-source interest | 0% withholding |
| Article 12 — Royalties | US-source royalties | 0% withholding |
| — Form 5472 (IRC §6038A) | Information reporting | Not a tax — treaty gives no relief |
Source: US-UK Double Taxation Convention (2001); IRC §6038A. Verified July 2026.
The US disregards your single-member LLC, but HMRC's view of a US LLC has been fact-specific since the Anson case — whether the LLC's profits are yours as they arise, or only when distributed, turns on the LLC's governing law and operating agreement. That determines your UK tax timing and your foreign tax credit position. It is squarely a UK adviser question — our scope is the US information return, and we do not give personal UK tax advice.
Fax Form SS-4 with "Foreign" on line 7b — the EIN arrives in about 4 business days. An ITIN (Form W-7) is only needed if you personally must file a US return — not for the LLC's EIN. London has IRS Certifying Acceptance Agents who can certify your UK passport.
| Situation | Route | Timing |
|---|---|---|
| No US tax ID (most UK founders) | Fax Form SS-4, write 'Foreign' on line 7b | ~4 business days |
| Personal US return needed (e.g., rental election) | Form W-7 for an ITIN — UK passport certified by a London CAA or HMRC-letter support | 7–11 weeks |
| Just the LLC's EIN for Form 5472 | SS-4 only — no ITIN required | ~4 business days |
Source: IRS Instructions for Forms SS-4 and W-7. Verified July 2026.
One UK-specific tip: make sure the name on your SS-4 matches your passport exactly — including middle names — because your bank and the IRS will both compare against it. The EIN belongs to the LLC and goes on the pro forma 1120 and Form 5472 every year.
UK founders are among the most widely accepted: Mercury and Relay open accounts fully online, and Wise Business and Revolut Business give you USD details with cheap GBP→USD conversion. High-street banks (Barclays, HSBC) handle the international wires.
Banking is rarely the bottleneck for a British founder. The fintech route (Mercury or Relay, opened with your EIN and articles) covers most needs; Wise Business or Revolut Business add multi-currency accounts with mid-market GBP→USD conversion for funding the LLC and repatriating distributions. If you prefer a traditional bank, Barclays and HSBC both run international desks used to US-UK structures.
Whichever you choose, route every owner-LLC flow through the LLC's US account — the initial funding wire (your reportable capital contribution), top-ups, and distributions. One clean account trail is what turns Form 5472 into simple reporting. The capital contribution guide shows why that first wire makes the form mandatory.
No. The UK has no remittance tax, and the new US 1% remittance excise tax (2026) targets cash-funded transfers — bank wires from the LLC's account are outside it. The UK-side change that matters is the April 2025 move from the remittance basis to the new FIG regime.
Moving pounds into the LLC and dollars back out are ordinary international wires — neither country taxes the movement itself. What changed for UK-resident owners is how the profits are taxed at home: from 6 April 2025, the UK abolished the remittance basis and replaced it with a residence-based system featuring a 4-year foreign income and gains (FIG) exemption for qualifying new arrivals. Long-term UK residents are now taxed on worldwide income as it arises — which can pull your LLC's profits into UK tax even when nothing is distributed.
That is an HMRC-side question for a UK tax adviser — it does not change the US filing, but it does change what your LLC costs you at home. The US side stays exactly as described on this page: Form 5472 every year, no income tax where Article 7 applies.
Report Form 5472 in US dollars at each transaction date. The hard part is the calendar: the US year ends December 31, the UK tax year ends April 5 — so one UK Self Assessment usually spans parts of two US LLC years. US deadline April 15; HMRC deadline January 31.
The UK is one of the few countries whose tax year does not match the US calendar year. Your LLC's Form 5472 always runs January–December, but for HMRC you report foreign income for the UK year April 6–April 5 — meaning the LLC's 2025 US calendar year lands partly in UK year 2024/25 and partly in 2025/26. Keep a monthly ledger in both GBP and USD so the split is arithmetic, not archaeology.
| Date | Country | What's due |
|---|---|---|
| April 15, 2026 | US (IRS) | Form 5472 + pro forma 1120 (or Form 7004 to extend to Oct 15) |
| April 5, 2026 | UK (HMRC) | UK tax year 2025/26 ends |
| January 31, 2027 | UK (HMRC) | Self Assessment return + balancing payment for 2025/26 |
Source: IRS and HMRC filing calendars, 2026. Verified July 2026.
Note also: a US LLC with no US office, inventory, or dependent agent usually has no US sales-tax or state nexus — and your UK VAT position on sales is a separate, unchanged UK matter.
A UK-owned single-member LLC cannot e-file. The package is mailed to 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201, or faxed to 855-887-7737. From the UK, international courier takes 2–4 days; an online fax gives instant confirmation.
| Method | Where | Proof to keep |
|---|---|---|
| Mail / courier | Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201 | Courier tracking (2–4 days from the UK) |
| Fax | 855-887-7737 | Fax transmission confirmation |
Source: IRS Instructions for Form 5472 (foreign-owned U.S. DE). Verified July 2026.
Full mechanics — including the pro forma 1120 cover sheet labeled “Foreign-owned U.S. DE” — are in the Form 5472 instructions and the how to submit Form 5472 guides.
The penalty is $25,000 per form, per year, per entity under IRC 6038A(d), with no cap and no statute of limitations. An additional $25,000 accrues every 30 days after a 90-day IRS notice.
Three ignored years can mean $75,000 — assessable indefinitely because the limitations clock never starts on an unfiled form. Model your exposure on the penalty calculator, read the penalty guide, and if you have missed years, start with the catch-up filing guide.
No. Under FinCEN's March 2025 interim final rule, US-formed entities — including UK-owned US LLCs — are exempt from BOI reporting. Form 5472 is separate and still required.
The BOI exemption does not reduce the Form 5472 obligation by one cent — different agency, different law. See the BOI vs Form 5472 comparison.
The IRS charges nothing, but one mistake costs $25,000. form5472.tax prepares and files Form 5472 plus the pro forma 1120 for a flat $299 — versus $547 at form5472.online and $1,999/year at doola.
| Provider | Price | What you get |
|---|---|---|
| form5472.tax | $299 | Form 5472 + pro forma 1120, specialist-reviewed, filed |
| form5472.online | $547 | Form 5472 + pro forma 1120 |
| doola | $1,999/year | Bundled annual compliance |
| Firstbase | $999–$1,499/year | Bundled annual compliance |
| DIY | $0 + risk | You prepare and mail it yourself |
Source: published provider pricing, July 2026.
We file the US information return; for the HMRC side — the April 5 mapping, FIG regime, and foreign tax credits — use a UK tax adviser with US experience. Start the US filing on the apply page.
Form 5472 and pro forma 1120, prepared, reviewed, and filed for a flat $299. Or message us first — we answer every question.