Which transactions a foreign-owned single-member LLC must report on Form 5472
For a foreign-owned single-member LLC, reportable transactions are dealings with you (the owner) or another related party of the kinds listed in Part IV, Part V or Part VI of Form 5472. Part V exists only for these LLCs and covers amounts paid or received in connection with the formation, dissolution, acquisition, and disposition of the entity, including contributions to, and distributions from, the entity IRS · checked Oct 27, 2026. The filing exception turns on whether any reportable transaction happened during the year, not on whether the LLC had income.
This page is for the non-US owner of a US single-member LLC that has not elected to be taxed as a corporation (a "foreign-owned U.S. DE" in IRS terms). For who must file, the due date and where to send the forms, see the Form 5472 filing guide.
Who counts as a related party
A reportable transaction is always a transaction between the LLC and a related party. The Form 5472 instructions define a related party to include any direct or indirect foreign shareholder of at least 25 percent. For a single-member LLC, that is you, the foreign owner. In Part II you report yourself as the foreign shareholder, and Part III describes the related party the transactions were with.
Other persons can also be related parties under the tax code's related-party rules (sections 267(b), 707(b)(1) and 482). If the LLC deals with a business or a person connected to you, ask a tax professional whether they are related. The instructions add: "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."
Transactions with a related party that is a US person are handled differently: the instructions say they are not required to be specifically identified in Parts IV, V and VI.
The three groups of reportable transactions
The instructions define a reportable transaction as any of the following during the LLC's tax year:
- Part IV: transactions paid only in money. Any type of transaction listed in Part IV where money (US or foreign currency) was the only payment. The list includes sales and purchases of goods (inventory) and other tangible property, rents and royalties, payments for intangible property such as patents and trademarks, payments for services, commissions, amounts borrowed and loaned, interest, insurance premiums, loan guarantee fees, and "other amounts" paid or received.
- Part V: other transactions of a foreign-owned DE. The instructions say you must check the box in Part V if you are a foreign-owned DE that had any other transaction, as defined in Regulations section 1.482-1(i)(7), not already entered in Part IV. They include amounts paid or received in connection with the formation, dissolution, acquisition, and disposition of the entity, including contributions to, and distributions from, the entity IRS · checked Oct 27, 2026.
- Part VI: transactions not fully paid in money. Transactions where some of the payment was not money, or where less than full value was paid. The LLC attaches a schedule that describes the property, rights and services exchanged and, if possible, gives a reasonable estimate of their fair market value.
The definition that Part V points to is broad. Regulations section 1.482-1(i)(7) says a "transaction" means any sale, assignment, lease, license, loan, advance, contribution, or any other transfer of property or money, however it is carried out and whether or not its terms are written down. It also includes services performed for the benefit of, or on behalf of, another taxpayer.
Common situations for a single-owner LLC
The table maps everyday situations to the text that covers them. Where the IRS texts do not name a situation, the table says so.
| What happened between you and the LLC | Where the IRS texts place it |
|---|---|
| You sent money from your own account to the LLC (for example, to fund its bank account) | Part V: a contribution to the entity. |
| The LLC sent money to you as owner | Part V: a distribution from the entity. |
| Money paid or received to set up the LLC | Part V: amounts paid or received in connection with the formation of the entity. |
| Closing the LLC and paying out what is left | Part V: amounts connected with the dissolution, and distributions from the entity. |
| You lent money to the LLC, or it lent money to you | Part IV: amounts borrowed or amounts loaned, and any interest paid or received. |
| The LLC paid you for services, or you paid the LLC for services, in money | Part IV: consideration paid or received for services. |
| The LLC bought goods from you or sold goods to you for money | Part IV: purchases or sales of inventory or other tangible property. |
| You paid an LLC bill from your personal account | Not named in the Form 5472 instructions. The Regulations section 1.482-1(i)(7) definition above covers transfers of money "however such transaction is effected". Ask a tax professional how to report it. |
The regulation's own example (Regulations section 1.6038A-2(b)(11), Example 1) follows a foreign corporation that forms a US LLC, which does not elect to be a corporation, and contributes assets to it in year 1, contributes more funds in year 2, receives a payment from the LLC in year 3, and receives the LLC's assets in liquidation in year 4. The regulation (which calls the LLC "X") concludes that each of the transactions in years 1 through 4 is a reportable transaction with respect to X LII · checked Oct 27, 2026, so the LLC has a reporting and record-keeping requirement for each of those years.
No income, no business: do you still file?
The instructions list one exception that can apply to a foreign-owned U.S. DE: it had no reportable transactions of the types in Parts IV and VI and, as a foreign-owned U.S. DE, also had no reportable transactions of the type listed in Part V of the form IRS · checked Oct 27, 2026. The regulation says the same thing in its own words: a reporting corporation is not required to file Form 5472 if it has no such transactions with any related party during the tax year (Regulations section 1.6038A-2(e)(1)).
- Income is not the test. The exception asks about transactions with related parties. The regulation also says the information must be furnished even though it may not affect the amount of any tax due under the Code LII · checked Oct 27, 2026.
- Check the formation year carefully. In the regulation's example above, forming the LLC and contributing assets to it in year 1 is a reportable transaction.
- A year with truly nothing between you and the LLC. If no money or property moved between you and the LLC and there were no other related party transactions, the exception above says no Form 5472 is required for that year. The instructions require the pro forma Form 1120 "with Form 5472 attached"; they do not separately address a year with no Form 5472. If you are unsure, ask a tax professional.
How to show the amounts
- US dollars and exchange rates. For Part IV, the instructions say to state all amounts in US dollars and attach a schedule showing the exchange rates used IRS · checked Oct 27, 2026. The regulation adds that statements must be in English.
- Part V amounts. Check the Part V box and follow the instruction: "Describe these on an attached statement IRS · checked Oct 27, 2026." Regulations section 1.6038A-2(b)(3) requires the dollar amounts of reportable transactions paid only in money, and its list of types includes these DE transactions (paragraph (b)(3)(xi)), so give the amounts, not only a description. The instructions also include Part V amounts in the line 1f total for a foreign-owned U.S. DE.
- Estimates. When actual amounts cannot be determined, the instructions allow reasonable estimates. A reasonable estimate is at least 75% but not more than 125% of the actual amount IRS · checked Oct 27, 2026. Part IV has a box to check if estimates are used.
- Small amounts. The Part IV instructions say that if an actual amount between the LLC and a foreign related party does not exceed a total of $50,000 IRS · checked Oct 27, 2026, it may be reported as "$50,000 or less IRS · checked Oct 27, 2026."
Examples
Ana lives in Portugal and forms Example Design LLC in Wyoming in March 2025. She sends $5,000 from her personal bank account to the LLC's new US account. In November the LLC sends $2,000 back to her. The $5,000 is a contribution and the $2,000 is a distribution, so both are Part V transactions. Ana's LLC files a pro forma Form 1120 with Form 5472 for 2025, checks the Part V box and attaches a statement describing both transfers with their US-dollar amounts.
Example Trading LLC is owned by Example GmbH, a German company. During 2025 the GmbH sells goods to the LLC for cash and lends it $40,000, and the LLC pays interest on the loan. The purchases, the loan and the interest are Part IV transactions (purchases of stock in trade, amounts borrowed, interest paid). Because each amount is in money, they go in Part IV, in US dollars, with the exchange-rate schedule if the amounts were in euros.
In 2026, Ana's LLC earns fees from unrelated US clients and pays its bills from its own account. Ana does not put money in or take money out, and the LLC has no other dealings with her or anyone related to her. Client fees from unrelated customers are not transactions with a related party, so under the first exception the LLC is not required to file Form 5472 for 2026. If Ana had paid the LLC's registered agent fee from her personal card, that falls in the row of the table that the instructions do not name, and she should ask a tax professional before deciding nothing is due.
If you left something out
The instructions say: "Filing a substantially incomplete Form 5472 constitutes a failure to file Form 5472 IRS · checked Oct 27, 2026." The penalty for not filing is $25,000 IRS · checked Oct 27, 2026. If a past return left out contributions, distributions or other transactions, see what to do if Form 5472 was late, missed or wrong. For the amounts and how the extra penalty grows, see Form 5472 penalties.