Form 5472 for Digital Nomads: Filing With No Fixed Tax Residence

Form 5472 follows your LLC and your status as a non-US person, not your location. If your US single-member LLC had a reportable transaction with you during the tax year, the filing is due with a pro forma Form 1120 — whether you spent the year in one country, four, or none. Having no tax residence anywhere removes nothing.

The pattern is familiar: a Wyoming or New Mexico LLC, a Mercury account, Stripe or Wise collecting client payments, and an owner who was in Bangkok in January and Lisbon by summer, with no country calling them a tax resident.

Two features of the no-fixed-residence position change the mechanics compared with a UK or Indian owner, who has a settled address and a national tax number. Neither removes the obligation: the FTIN box asks for a tax number you may not have, and the address fields ask separately where the LLC is and where you are.

If you want the filing done rather than explained, we prepare and fax the complete package from $149.

Does a digital nomad with no tax residence still file Form 5472?

Yes. The test has three conditions, and none is about where you live:

1. The LLC is a US disregarded entity — a single-member LLC that has not elected corporate treatment.
2. Its sole member is a non-US person: not a US citizen, green card holder or US tax resident.
3. There was at least one reportable transaction during the year between the LLC and its owner or another foreign related party.

Under Treasury Regulation § 1.6038A-1, for tax years beginning on or after 1 January 2017 and ending on or after 13 December 2017, a foreign-owned US disregarded entity is treated as a corporation separate from its owner solely for the § 6038A reporting rules. The rule has no residence condition.

Reportable transactions include movements between you and your own LLC: contributions, distributions, loans either way, and other related-party transactions. An unrelated customer's payment is not a related-party transaction merely because it comes from abroad. Disclose related customers separately. A transfer from the LLC to your personal account needs its own classification and reporting review under the IRS instructions.

More cases: reportable transaction examples.

The IRS instructions state that a $25,000 penalty may apply for failure to file when due and in the prescribed manner, and that a substantially incomplete Form 5472 counts as a failure to file.

Why does the 183-day rule not decide your Form 5472 obligation?

Because the 183-day rule nomads discuss constantly is a local residency test, and Form 5472 does not use it.

Countries have their own tax-residency tests, which may include day counts, homes, and other connections. There is no universal 183-day exemption. Those local tests do not replace the separate U.S. review of the entity, owner status, and reportable transactions.

Claiming no tax residence elsewhere does not establish that you are a foreign person for U.S. purposes. U.S. citizenship, green-card status, substantial presence, and applicable elections or exceptions need their own review. A U.S. citizen abroad does not become a foreign person simply by travelling.

What goes in the FTIN box if no country has given you a tax number?

Enter "None" or "N/A" in the FTIN block and a self-assigned reference ID number on the line above it.

The instructions for Form 5472 require a reference ID only where no US identifying number is entered, limit it to 50 alphanumeric characters with no spaces or special characters, and require the same ID every year for the same person. If you have no FTIN, they say to enter "None" or "N/A".

If a country has issued you a personal tax number, such as a Portuguese NIF, you generally have an FTIN to enter even after leaving; the box asks whether the number exists. Do not get an ITIN just to fill the field. Details: our FTIN and reference ID guide.

What address do you use when you have no settled address?

Use the LLC's real address in the reporting-entity section and your own current address in the owner section. They are separate fields.

Part I identifies the LLC; Part II identifies you. Copying the LLC's US registered-agent address into the owner field defeats the purpose of Part II and sits oddly beside the claim that you are a foreign person.

With no fixed home, use the address where you actually are or genuinely receive correspondence, consistent with your bank and EIN records. A mail-forwarding address is a mailing arrangement, not residence. See our address guide and the separate fields on the current Form 5472.

When does time in the United States change the whole picture?

When your days in the United States meet the substantial presence test — because you may then stop being a foreign person, and everything above assumes you are one.

The IRS says you are a US resident for tax purposes if you meet the test for the calendar year: physical presence on at least 31 days during the current year and 183 days during the 3-year period that includes the current year and the 2 years immediately before that, counting all current-year days, one-third of the days in the first year before, and one-sixth of the days in the second year before (IRS substantial presence test).

The IRS's own example: 120 days in each of 2023, 2024 and 2025 gives 120 + 40 + 20 = 180, which does not meet the test for 2025. Any part of a day counts as a day of presence, though the page lists exclusions, such as transit of under 24 hours between two places outside the US and days as an exempt individual.

That weighting is the trap: four months a year feels casual, but repeated across three years it crosses the threshold.

Meeting the test does not mean you simply stop filing. Residency starting dates have their own rules, a closer-connection exception or treaty position can apply in defined cases, and the foreign-ownership test looks at the whole tax year (IRS residency starting and ending dates). Involve a qualified adviser and read when a Form 5472 owner becomes a US tax resident.

The four-question self-check: is a Form 5472 due for this year?

Answer in order and stop at the first row below that matches. The resolution rule: questions 1 to 3 must all be "yes" for a filing to be required; question 4 only decides whether that filing is still outstanding.

1. Was the entity a US LLC with one owner and no corporate tax election, all year?
2. Were you a non-US person all year — no US citizenship, green card, substantial presence or election to be treated as resident?
3. Did any reportable transaction occur between the LLC and you or another foreign related party?
4. Has a complete Form 5472 with pro forma Form 1120 already been filed for that year?

Every combination lands on exactly one row. Absent from the list: where you slept, days spent outside the US, whether any country issued you a tax number, and whether the LLC made a profit.

Which country guide applies to you?

Local rules change what goes in the FTIN box and what you owe at home, not the US filing.

Which nomad questions have their own guide?

Practical records guides by digital-nomad destination

These city-focused guides address specific recordkeeping and adviser-handoff decisions. They are not rankings of nomad populations or promises of local tax exemptions.

How does a nomad actually file Form 5472?

You cannot e-file. A foreign-owned US DE files on paper.

1. Prepare the pro forma Form 1120 with "Foreign-owned U.S. DE" across the top of page 1. Only the name, address and items B and E are required.
2. Prepare Form 5472 — Part I for the LLC, Part II for you with the FTIN entry and reference ID, and the transaction parts with a statement itemising contributions and distributions.
3. Convert amounts to US dollars at a consistent, reasonable rate and state the basis.
4. Sign, then fax to 855-887-7737, or mail to Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201.
5. Keep the timestamped transmission receipt where you can reach it from anywhere.

The due date for a calendar-year entity is generally 15 April; Form 7004 extends it. See the 2026 deadline guide.

Getting it filed from anywhere

The hard part on the road is faxing internationally and keeping the reference ID identical to last year's.

We prepare the package, have it reviewed by a qualified tax accountant, and fax it to the Ogden PIN Unit, returning a timestamped receipt — transmission evidence, not IRS acceptance. $149 standard (5–7 business days), $199 express (within 3 business days), +$99 per additional past year, IRS fax delivery included; see pricing.

We are not a CPA firm and do not give tax advice, and we do not advise on any country's personal tax.

Frequently asked questions

I am not a tax resident anywhere. Do I still file Form 5472?

Yes, if you are a foreign person for U.S. tax purposes and your U.S. disregarded LLC had a reportable related-party transaction. Having no tax residence elsewhere does not establish foreign-person status or remove the filing obligation.

Does staying under 183 days in every country help?

Not with this filing. Those are local residency tests other countries use for their own taxes. Form 5472 is a US information return and uses no country's day count.

What FTIN do I use if no country has issued me a tax number?

Enter "None" or "N/A" in the FTIN block and a self-assigned alphanumeric reference ID on the preceding line. Reuse the same ID every year.

Can one virtual mailbox address serve for both the LLC and me?

Treat them as separate fields: the LLC's section takes the entity's real address, the owner section takes yours. A mail-forwarding address is not a residence.

How many days in the United States is too many?

The substantial presence test is met at 31 days this year plus 183 weighted days over three years: all current-year days, one-third of last year's, one-sixth of the year before. Meeting it can make you a US tax resident.

My LLC had no money movement at all. Do I file?

If no reportable transaction occurred, Form 5472 is not required that year. Keep the bank statements that show it.

I have travelled for three years and never filed. What now?

File every outstanding year promptly with a reasonable cause statement, before the IRS contacts you. See our late filing guide.

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Your itinerary is not a variable in this filing. The LLC is American, you are a foreign person, and money moved between you — that is the whole test, from Chiang Mai or anywhere else.

Start your filing in about 15 minutes, or read the filing requirements checklist first.

Educational content only; not tax or legal advice.