Form 5472 for German Owners of a US LLC
German owners of a single-member US LLC may need Form 5472 and a pro forma 1120. Learn the owner-ID, transaction and filing rules.
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Last updated August 19, 2026
A German resident who wholly owns a US single-member LLC generally must file Form 5472 with a pro forma Form 1120 when the LLC has a reportable transaction with the owner or another related party. The obligation can arise from capital contributions, withdrawals, loans or owner-paid expenses even if the LLC has no income.
Form 5472 is a US related-party information return, not a German tax return. The IRS Form 5472 instructions state that a required Form 5472 filed late, filed substantially incomplete, or not supported by required records can trigger a $25,000 penalty. German owners who already know they need the US package can begin the US filing here.
When does a German-owned LLC file Form 5472?
A German-owned LLC generally files Form 5472 when it is a domestic disregarded entity wholly owned by a foreign person and it had at least one related-party reportable transaction during the tax year. The IRS instructions treat a foreign-owned US disregarded entity as a reporting corporation for the limited purposes of section 6038A.
Use this test before preparing the return:
- The LLC was formed under US state law.
- The LLC had one owner for US federal tax purposes.
- The owner was a German individual, German company, or other non-US person.
- The LLC did not elect corporate tax treatment for the year.
- The LLC had a transaction with the owner or another related party.
German owners often focus on sales, invoices and profit. Form 5472 focuses on related-party movement. Formation funding, owner loans, owner withdrawals, reimbursements and personally paid LLC costs can all matter even when the LLC had no taxable profit.
For a calendar-year LLC, the 2025 Form 5472 package was generally due on 15 April 2026 under the IRS Form 5472 instructions. A timely Form 7004 extension generally moved that deadline to 15 October 2026. The IRS instructions say a foreign-owned US disregarded entity requests the extension by filing Form 7004 by the regular due date and writing "Foreign-owned U.S. DE" across the top.
Which German tax number belongs on Form 5472?
For a German individual, the FTIN is generally the personal tax identification number, the Identifikationsnummer or IdNr. Germany's Federal Central Tax Office says the tax identification number identifies the taxpayer in the taxation procedure, is assigned automatically to newborn children and new citizens on first registration, and remains valid for life in its BZSt IdNr guidance.
Do not confuse the owner identifier with the LLC identifier:
| Filing field | German-owner answer |
|---|---|
| LLC EIN | The US entity's Employer Identification Number |
| Individual owner FTIN | German IdNr, when applicable |
| German entity owner FTIN | The entity's relevant German tax identifier |
| Owner US identifying number | SSN, ITIN or EIN only if one already exists for the owner |
| Reference ID number | A consistent filer-created ID where required by the IRS instructions |
An individual owner does not need to obtain an ITIN solely to file Form 5472. The LLC needs an EIN. The owner uses the German FTIN and reference-ID process unless the owner already has a US identifying number for another reason.
What does the US-Germany treaty change for Form 5472?
The US-Germany income tax treaty may affect whether the German owner owes US income tax on business profits, but it does not cancel Form 5472. The IRS treaty A-to-Z page lists Germany among countries with US income tax treaty documents.
Treaty analysis belongs in the income-tax lane. Form 5472 belongs in the information-return lane. A German consultant with no US office may have a strong treaty and domestic-law position on US income tax, while still having an annual Form 5472 requirement because owner contributions and distributions were reportable transactions.
| Issue | German owner should ask | Form 5472 result |
|---|---|---|
| US business profits | Does a US trade or business or permanent establishment exist? | Separate from the filing requirement |
| Related-party funding | Did the owner fund the LLC or pay LLC costs personally? | Usually relevant |
| Owner withdrawals | Did the LLC send money or property to the owner? | Usually relevant |
| Treaty protection | Does the treaty reduce or eliminate US income tax? | Does not eliminate Form 5472 |
| German taxation | How does Germany classify and tax the LLC result? | Separate local advice |
Form5472 Prep is not a CPA firm and does not give tax advice. A German Steuerberater or other qualified adviser should handle German classification, trade-tax, VAT and treaty questions. A US tax professional should review any fact pattern with US staff, US inventory, US services or US real estate.
What transactions should a German owner report?
A German owner should report transactions between the LLC and related parties, not every unrelated customer receipt. The owner is a related party. A German company under common control can also be a related party. Build the Form 5472 workpaper from bank statements, owner accounts and reimbursement records.
Review these categories:
| Transaction type | Examples | Common evidence |
|---|---|---|
| Contributions | EUR transfer to fund Mercury, Wise or another LLC account | Bank transfer, formation records |
| Distributions | LLC sends cash to the German owner | Bank transfer, owner ledger |
| Loans | Owner advances money, LLC repays principal or interest | Loan note, repayment schedule |
| Reimbursements | LLC reimburses a personal-card payment | Invoice, card statement, repayment |
| Services or property | Related party provides management, IP, equipment or rent | Agreement, valuation support |
| Lifecycle transactions | Formation, acquisition, sale or dissolution | State filings, purchase or closing documents |
The German owner's profit-and-loss report is still useful, but it does not answer the Form 5472 question by itself. A customer payment from an unrelated buyer is different from a distribution to the owner. A bill paid by a personal German card is different from a bill paid directly by the LLC.
How are euro transactions translated into US dollars?
Euro transactions should be translated into a US-dollar schedule that ties each Form 5472 amount back to the original record. The IRS instructions ask for US-dollar totals for related-party transaction values, so the workpaper should preserve the date, EUR amount, rate source, USD amount and classification.
Here is a worked example:
| Transaction | Original amount | Working | Form 5472 workpaper amount |
|---|---|---|---|
| Owner capital contribution | EUR 2,500 | EUR 2,500 x 1.0900 | USD 2,725 |
| Owner draw | EUR 900 | EUR 900 x 1.0800 | USD 972 |
| Owner-paid software bill | USD 240 | Already in USD | USD 240 |
| Total related-party value reviewed | USD 2,725 + USD 972 + USD 240 | USD 3,937 |
The exchange rates in the example are illustrative. Replace them with documented rates from the relevant dates or another consistently used published source accepted by your preparer. The main audit point is not choosing a convenient rate; it is keeping a repeatable conversion trail.
How does a German owner complete the filing?
The filing package is prepared as a pro forma Form 1120 with Form 5472 attached. The IRS instructions say foreign-owned US disregarded entities write "Foreign-owned U.S. DE" across the top of Form 1120 and file by fax at 300 DPI or higher to 855-887-7737, or by mail to the dedicated Ogden PIN Unit address.
Follow this procedure:
- Confirm the owner, tax classification and tax year.
- Collect the LLC EIN and the German owner's IdNr or entity FTIN.
- Reconcile every related-party transfer in both directions.
- Convert EUR and other non-USD amounts into a saved USD schedule.
- Prepare the pro forma Form 1120 using the limited required entity information.
- Prepare Form 5472 and a Part V attachment describing formation, contributions, distributions and other relevant transactions.
- Fax or mail the signed package to the dedicated Ogden PIN Unit address from the IRS instructions.
- Keep the complete package, transaction ledger and timestamped delivery evidence.
The signed package is not complete just because the PDF exists. German owners should keep proof that the IRS received the fax or mailing, because late or missing Form 5472 filings can be assessed by year and by form.
How should a German owner think about German tax?
German tax treatment is separate from Form 5472, and a German resident should not assume the US disregarded-entity answer controls the German answer. Germany's Income Tax Act states the unlimited income-tax liability rule in §1 EStG, subject to treaty or other special rules.
That local question can involve more than income tax. German trade tax, VAT, bookkeeping and entity classification require German professional advice. The US filing question stays narrower: a foreign-owned US disregarded entity with a reportable related-party transaction generally files Form 5472 even if the owner believes no US income tax is due.
Four scenarios, worked through
German consultant, Wyoming LLC, all services performed in Berlin. The owner bills international clients through the LLC and has no US office or US personnel. US income-tax and treaty questions depend on the full facts, but the owner contributed EUR capital and later withdrew cash. Form 5472 is generally required for those related-party transactions.
German ecommerce seller, Delaware LLC, goods held in a US warehouse. US inventory creates a serious US income-tax question. The Form 5472 filing does not wait for that question to be solved. Owner loans, repayments, reimbursements and distributions should still be reconciled for the US information return.
German SaaS founder, New Mexico LLC, no revenue in 2025. The owner paid formation and registered-agent invoices personally and had no customer sales. The personally paid LLC expenses can still be related-party transactions. The 2025 package was generally due 15 April 2026, or 15 October 2026 with a timely extension.
German owner dissolving a dormant LLC. The LLC had no current business, but final expenses were paid personally and remaining funds were moved back to Germany. Dissolution-year transfers should be reviewed before the owner treats the US compliance history as finished.
How can Form5472 Prep be the answer?
Form5472 Prep handles the US filing mechanics when the German owner has already identified the related-party activity and needs the annual package prepared correctly. The service prepares Form 5472, the pro forma Form 1120 and the Part V statement, and the package is reviewed by a qualified tax accountant.
After signature, Form5472 Prep faxes the package to the IRS Ogden PIN Unit at 855-887-7737 and returns a timestamped receipt. Standard service is $149 and takes 5-7 business days. Express service is $199 and takes 3 business days. Each additional past tax year is +$99. Fax delivery is included.
If the LLC still needs an EIN, the EIN service is $149 at /ein. Form5472 Prep is not a CPA firm and does not give German or US tax advice, but it does prepare and submit the information-return package German owners often cannot e-file themselves.
Frequently asked questions
Is a German IdNr the same as the LLC's EIN?
No. The German IdNr identifies the owner. The EIN identifies the US LLC. Form 5472 keeps those identifiers in separate fields.
Does a German owner need an ITIN for Form 5472?
Usually no. The LLC needs an EIN. A German individual owner generally uses the IdNr as the FTIN and a reference ID where required.
Does a dormant German-owned LLC file Form 5472?
It may. Owner funding, withdrawals, personally paid invoices, reimbursements, loans and closure transactions can create a Form 5472 obligation even when the LLC had no sales.
Does the US-Germany treaty remove Form 5472?
No. The treaty can matter for US income-tax analysis, but Form 5472 is a separate information return for reportable related-party transactions.
Can a German owner e-file Form 5472?
No. Under the IRS instructions, a foreign-owned US disregarded entity cannot file Form 5472 electronically. The package is faxed or mailed to the Ogden PIN Unit.
Does Form 5472 decide German tax treatment?
No. Form 5472 is US information reporting. German income tax, trade tax, VAT and bookkeeping consequences require separate German professional advice.
What should German owners do next?
The safest starting point is a complete owner ledger, not a profit-and-loss report. Start your filing, or see how Form 5472 is completed part by part before preparing the package.