IRS (IRC §6038A)
IRS Form 5472 (foreign-owned US LLC / 25%-foreign-owned US corp)
An information return reporting transactions between a 25%-foreign-owned US corporation (or a foreign-owned US disregarded entity, e.g. a single-member LLC) and its related parties. A foreign-owned single-member US LLC files a pro-forma Form 1120 with Form 5472 attached, even with no US income tax otherwise due.
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This is general information, not legal or tax advice. Deadlines and penalties change and depend on your specific facts — verify with the official source and a licensed CPA or attorney before acting.
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date we last verified it. Sources change; always confirm against the linked official page.
- What it is
- An information return reporting transactions between a 25%-foreign-owned US corporation (or a foreign-owned US disregarded entity, e.g. a single-member LLC) and its related parties. A foreign-owned single-member US LLC files a pro-forma Form 1120 with Form 5472 attached, even with no US income tax otherwise due.
- Who must file
- 25%-foreign-owned US corporations; foreign-owned single-member US LLCs (disregarded entities); and foreign corporations engaged in a US trade or business, that had reportable transactions with related parties.
- Deadline
- Filed with Form 1120 (or pro-forma 1120) by the 15th day of the 4th month after the entity's tax year-end — about April 15 for a calendar-year filer — including extensions.
- Penalty if missed
- $25,000 for failure to file a complete and accurate return, plus an additional $25,000 for each 30-day period the failure continues more than 90 days after IRS notice.
- Notes
- This is the obligation that most often blindsides foreign founders of US LLCs: the LLC may owe no US income tax yet still face a $25,000 penalty for not filing the pro-forma 1120 + 5472.
- Official source
- IRS — Instructions for Form 5472 — verified as of 2026-06-22