Form 5472 for a foreign-owned single-member LLC: how to file, step by step

This page is for a non-US individual or company that owns all of a US limited liability company (LLC) with no election to be taxed as a corporation. It does not cover LLCs with two or more members, LLCs that filed Form 8832 to be treated as a corporation, or owners who are US citizens or US tax residents.

Does your LLC have to file?

Three definitions decide this:

• Disregarded entity (DE): an entity ignored as separate from its owner for US income tax. The IRS page on single-member LLCs says a one-member LLC is treated this way unless it files Form 8832 and elects to be a corporation.
• Foreign person (Form 5472 instructions): among others, an individual who is not a US citizen or resident, and a company not created or organized in the United States.
• Foreign-owned U.S. DE: a domestic DE that is wholly owned by a foreign person IRS · checked Oct 27, 2026.

For tax years beginning on or after January 1, 2017, and ending on or after December 13, 2017 IRS · checked Oct 27, 2026, a foreign-owned U.S. DE is treated as an entity separate from its owner and classified as a corporation, but only for the limited purposes of the section 6038A reporting rules behind Form 5472.

The general rule is that a reporting corporation must file Form 5472 if it had a reportable transaction with a foreign or domestic related party IRS · checked Oct 27, 2026.

So the question is whether anything reportable happened between the LLC and you during the year. Part V covers money you put into the LLC or take out of it, and amounts connected with forming or closing it. Details and examples: which transactions count as reportable.

What you file: a pro forma Form 1120 with Form 5472 attached

The instructions explain that a foreign-owned U.S. DE has no income tax return filing requirement IRS · checked Oct 27, 2026, but it must file a pro forma Form 1120 with Form 5472 attached.

1. On Form 1120, fill in only what is required. The instructions say the only information required is the name and address of the foreign-owned U.S. DE and items B and E IRS · checked Oct 27, 2026 on the first page. Item B is the LLC's employer identification number (EIN). Item E is a row of check boxes: initial return, final return, name change, address change.
2. Mark the top of the page. The instructions say: “Foreign-owned U.S. DE” should be written across the top of the Form 1120 IRS · checked Oct 27, 2026.
3. Complete Form 5472 for the LLC. Check the box on line 3 that says the reporting corporation is a foreign-owned U.S. DE. In Part II, report the foreign owner on the lines for the foreign shareholder, as the instructions direct for a DE. Complete Part III for the related party even if it is the same person you listed in Part II; the instructions say all filers must do this.
4. Report the transactions. Transactions with the foreign related party paid only in money go in Part IV. Transactions paid in something other than money, or for less than full value, go in Part VI with an attached description. Part V is only for foreign-owned DEs; check its box and describe those transactions on an attached statement. All reporting corporations complete Part VII, but the instructions say a foreign-owned U.S. DE does not complete lines 43a and 43b.
5. One Form 5472 per related party. The instructions say: File a separate Form 5472 for each foreign or U.S. person who is a related party with which the reporting corporation had a reportable transaction IRS · checked Oct 27, 2026.
6. Use English and US dollars. The regulation says statements filed with Form 5472 must be in the English language LII · checked Oct 27, 2026. For Part IV, the instructions say to use US dollars and attach a schedule showing the exchange rates used IRS · checked Oct 27, 2026.

What to have ready before you start

These follow what Parts I to V of Form 5472 ask for.

About the LLC

• The LLC's EIN. Form 1120 item B and Form 5472 both ask for it. The Form 1120 instructions say a corporation that does not have an EIN must apply for one. If you have no SSN or ITIN, see how to get an EIN without an SSN.
• Basic company details: name and address, country and date of incorporation, main business activity and its code (the code list is in the Instructions for Form 1120), and the countries where business is conducted (the instructions say not to write "worldwide"). There is also a check box for the first year the LLC files Form 5472.

About you, the owner

• Name, address and countries: citizenship (or organization), where you conduct business, and where you file income tax returns as a resident.
• A US identifying number, if you have one: an SSN or ITIN for an individual, an EIN for an entity.
• If you have no US number, a reference ID number. You create it; the instructions say there is no need to apply to the IRS. Letters and numbers only, no spaces or special characters, limited to 50 characters IRS · checked Oct 27, 2026, and the same number every year.
• Your foreign tax identification number (FTIN). A foreign-owned U.S. DE must enter it if there is one. If not, the instructions say to enter “None” or “N/A” IRS · checked Oct 27, 2026.

About the money

A list of every transaction between the LLC and you during the tax year (for example, money you paid in, money the LLC paid you, loans, payments for services), with the exchange rates for any amounts not in US dollars.

Tax year and due date

Tax year. A foreign-owned U.S. DE has the same tax year used by its owner for U.S. tax filing requirements or, if none, the calendar year IRS · checked Oct 27, 2026. So if you, the owner, have no US tax filing requirement of your own, the LLC uses the calendar year.

Due date. Form 5472 is due with the pro forma Form 1120, by the due date (including extensions) of that Form 1120. The Instructions for Form 1120 say a corporation must generally file by the 15th day of the 4th month after the end of its tax year IRS · checked Oct 27, 2026. If the due date falls on a Saturday, Sunday, or legal holiday, the corporation can file on the next business day IRS · checked Oct 27, 2026.

Getting more time with Form 7004

The Form 5472 instructions say a foreign-owned U.S. DE can request more time by filing Form 7004, and the DE must file Form 7004 by the regular due date of the return IRS · checked Oct 27, 2026. The Form 7004 instructions say the automatic extension period is generally 6 months IRS · checked Oct 27, 2026.

1. Enter the right form code. Because Form 5472 is attached to the pro forma Form 1120, the code for Form 1120 should be entered on Form 7004, Part I, line 1 IRS · checked Oct 27, 2026. On the current Form 7004, the code listed for Form 1120 is 12 IRS · checked Oct 27, 2026.
2. Mark the top. The Form 5472 instructions say: “Foreign-owned U.S. DE” should be written across the top of Form 7004 IRS · checked Oct 27, 2026.
3. Match the IRS records. The Form 7004 instructions warn that if the name does not match the IRS database or the identifying number is wrong, you will not have a valid extension IRS · checked Oct 27, 2026.
4. Fill in the tax year and the tax lines. Show the calendar year, or the start and end dates if you do not use a calendar year. For the tentative total tax line, the Form 7004 instructions say: If you expect this amount to be zero, enter -0- IRS · checked Oct 27, 2026.
5. Send it the special way. The DE must fax or mail the Form 7004 to the fax number or mailing address identified earlier IRS · checked Oct 27, 2026 (the Form 5472 fax number and address in the next section). The instructions add: "For these entities, do not use the regular filing address listed in the Instructions for Form 7004 IRS · checked Oct 27, 2026."
6. Do not wait for an approval. The Form 7004 instructions say "No signature is required on this form IRS · checked Oct 27, 2026" and "We will notify you only if your request for an extension is disallowed IRS · checked Oct 27, 2026."

How to send it: fax or mail only

The instructions say that if you are a foreign-owned U.S. DE, you cannot file Form 5472 electronically IRS · checked Oct 27, 2026. Send the pro forma Form 1120 with Form 5472 attached in one of two ways:

• Fax to 855-887-7737 IRS · checked Oct 27, 2026, at 300 DPI or higher IRS · checked Oct 27, 2026.
• Mail to the dedicated address:
  Internal Revenue Service 1973 Rulon White Blvd M/S 6112 Attn: PIN Unit Ogden, UT 84201 IRS · checked Oct 27, 2026

The Form 5472 instructions add: These filers do not use the mailing address provided in the Instructions for Form 1120 IRS · checked Oct 27, 2026. The Form 1120 instructions say to keep copies of all filed returns.

Records you must keep

The Form 5472 instructions say a reporting corporation must keep permanent books or records, as section 6001 requires, sufficient to establish the correctness of its federal income tax return, including records relevant to transactions with related parties.

• No small-company exemption for a foreign-owned DE. The instructions mention special record rules for small corporations and for small-value related party transactions (Regulations section 1.6038A-1(h) and (i)). Both exclude an entity treated as a corporation under section 301.7701-2(c)(2)(vi), which is the rule that makes a foreign-owned DE a reporting corporation.
• Where to keep them. Under Regulations section 1.6038A-3, the records must be maintained within the United States LII · checked Oct 27, 2026 unless certain conditions are met. One of those conditions for records kept outside the United States is delivering requested documents to the IRS within 60 days of the request by the Service for such records LII · checked Oct 27, 2026.
• What kinds. The regulation's list includes general ledgers, bank statements, sales contracts and purchase invoices, to the extent relevant to transactions with foreign related parties.
• How long. As long as they may be relevant or material to the tax treatment of a transaction with a related party, but in no case less than the applicable statute of limitations on assessment and collection LII · checked Oct 27, 2026. The Form 5472 instructions also say records relating to a form must be kept as long as their contents may become material in the administration of any Internal Revenue law IRS · checked Oct 27, 2026.

Not keeping the required records can trigger the same penalty as not filing (penalties).

If something went wrong

• Missed a year, filed late, or sent an incomplete form: see what to do if Form 5472 is late or missed.
• Penalty amounts: see the penalty table.
• Not sure whether a payment counts: see reportable transactions, and ask a tax professional (a CPA, an enrolled agent, or a tax attorney) if your case does not fit.
• Rather not prepare it yourself: a filing service can prepare the forms for you. See our comparison of Form 5472 filing services.

Related pages

• Which transactions a foreign-owned LLC must report
• Form 5472 filed late or missed: what to do
• Form 5472 penalties
• A foreign-owned LLC's yearly US tasks