Form 5472 for UK Residents Who Own a U.S. LLC: What You Actually Need to File

If you're based in the UK and you own a US single-member LLC — Wyoming, Delaware, New Mexico, it doesn't matter — the IRS almost certainly requires you to file Form 5472 every year. This is not an income tax return. You don't pay anything. But the penalty for not filing is $25,000 per form, per year, with no cap on continuation penalties.

This guide covers exactly what applies to UK residents specifically: what to file, what counts as a reportable transaction (including Wise transfers), when it's due, and what's changed recently with BOI reporting.

TL;DR — Key Facts for UK LLC Owners

You must file Form 5472 if you're a UK resident who owns a US single-member LLC and had any money move between you and the LLC during the year.
The filing vehicle is Form 5472 attached to a pro forma Form 1120 (a mostly blank US corporate return with "Foreign-Owned U.S. DE" written across the top).
The deadline is April 15 of the following year, extendable to October 15 by filing Form 7004 first.
Zero revenue does not mean zero filing obligation. The capital you wired into the LLC when you opened it is a reportable transaction.
BOI reporting to FinCEN is NOT required for US-formed LLCs as of March 26, 2025 — most guides you'll find online have this wrong.

Does this apply to you?

Three things need to be true:

You own a US single-member LLC.
You are not a US person — meaning you're not a US citizen, green card holder, or US tax resident.
There was at least one reportable transaction between you and the LLC during the tax year.

If all three are true, you must file. Living in the UK, not having a US bank account, not having any US customers — none of that changes the obligation.

The tricky one is point three. "Reportable transaction" is broader than most people expect. It is not just revenue.

What counts as a reportable transaction if you're in the UK?

Reportable transactions are defined in 26 CFR §1.6038A-4 and cover any money, property, or services exchanged between the LLC and a foreign related party (you).

Things that count:

The initial wire from your UK bank account to open the LLC's US bank account (a capital contribution)
Any further transfers you make into the LLC from your UK account
Any distributions the LLC pays back to your UK account
Payments the LLC makes to you for services (e.g. a consulting fee)
Loans in either direction between you and the LLC

Things that don't count:

Revenue from your customers hitting the LLC's bank account
Stripe, PayPal, or Paddle payouts that stay within the LLC
Operating expenses the LLC pays to third parties

A concrete example: you're a UK-based developer. You opened a Wyoming LLC to receive USD payments from US clients. To open the Mercury account, you wired £500 ($630) from your Barclays account. That wire is a reportable transaction. The $50,000 of client revenue sitting in Mercury is not. But when you send any of it back to yourself via Wise, that distribution is a reportable transaction.

Wise transfers specifically: A Wise or Revolut transfer from the LLC's US account to your UK personal account is a distribution — reportable. A transfer from your UK account into the LLC is a contribution — also reportable. The IRS doesn't care what payment rail you use.

What do you actually have to file?

Two documents, submitted together:

1. Pro forma Form 1120 — this is the US corporation income tax return, but you don't fill most of it in. You complete the entity identification section at the top (LLC name, EIN, US address, formation date, year-end total assets) and write "Foreign-Owned U.S. DE" in bold across the top of page 1. That's it. No income figures. No deductions. It's purely a structural envelope for Form 5472.

2. Form 5472 — the actual information return. You fill in:

Part I: entity details (LLC) and owner details (you, as a UK resident)
Part II: the ownership structure
Part III: a declaration of whether you have related-party transactions
Part IV / V / VI: details of each reportable transaction — the amounts, the dates, the nature
Part VII: a signature

You attach Form 5472 to the pro forma 1120 and file them together.

When is it due, and how do you actually file?

Deadline: April 15 of the year following the tax year. For the 2025 tax year, that's April 15, 2026.

Extension: File Form 7004 by April 15 and you get an automatic 6-month extension to October 15, 2026. No explanation required, just the form.

Method: You cannot e-file. The IRS does not accept electronic filing for foreign-owned disregarded entity returns. Your options are:

Fax (faster, recommended): fax to the IRS Ogden PIN Unit at +1-855-887-7737, minimum 300 DPI resolution. You get a transmission receipt, which is your proof of timely filing.
Mail: 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201. Certified mail is advisable — you'll want proof of postmark.

The penalty — what it actually costs UK founders

The IRS assesses a $25,000 penalty per Form 5472, per year, automatically under IRC §6038A(d). You don't have to do anything special to trigger it — miss the deadline, and the penalty is assessed.

Worse: if the IRS sends you a notice and you don't file within 90 days of receiving it, you owe an additional $25,000 for each 30-day period after that 90-day window. There is no cap.

So a UK founder who hasn't filed for three years, gets an IRS notice, and ignores it for another six months could realistically face penalties in the hundreds of thousands of dollars on a business that never turned a profit.

The mistake we see most often: people assume that because the LLC had no US income, no US tax return is required, so nothing needs to happen. That logic applies to income tax. Form 5472 is an information return — it reports transactions, not taxable income. The two obligations are completely separate.

Already missed a year? File under the DIIRSP procedure (Delinquent International Information Return Submission Procedure) with a reasonable cause statement. The IRS reviews these individually — it is not a free pass, but filing late with a strong statement is vastly better than not filing at all.

Ready to get it filed?

Form5472 Prep prepares your Form 5472 and pro forma Form 1120, generates the reasonable cause statement if you're filing late, and faxes the signed package to the IRS Ogden PIN Unit on your behalf.

From $79 + $19 IRS fax delivery fee. Takes about 15 minutes. 100% money-back guarantee if we fail to submit.

Get your Form 5472 filed →

What about BOI reporting to FinCEN?

Many guides you'll find online — including some published by US CPAs — still instruct UK LLC owners to file a Beneficial Ownership Information (BOI) report with FinCEN under the Corporate Transparency Act.

This is outdated. On March 26, 2025, FinCEN revised its rules to exempt all US-formed entities from BOI reporting. A Wyoming LLC or Delaware LLC formed under US state law is a domestic entity — it is now exempt from FinCEN BOI filing.

The remaining BOI obligation applies only to foreign companies (formed under the law of a foreign country) that have registered to do business in a US state. A UK-resident who owns a Wyoming LLC does not trigger this obligation — the LLC itself is the US entity, and it's now exempt.

Note: This rule was published as an interim final rule and FinCEN has indicated it intends to finalize it. This post reflects the status as of May 2026 — confirm at fincen.gov/boi if you're filing after this date.

What about UK tax on your LLC income?

A common question, though technically outside the scope of Form 5472: do you owe UK tax on what the US LLC earns?

Short answer: probably yes, because HMRC generally taxes UK residents on their worldwide income, and a US LLC that's a disregarded entity for US purposes doesn't create a US income tax liability for a non-US owner — but it may well create a UK income tax (or capital gains) liability depending on how the income is classified.

This is a separate issue from your Form 5472 obligation. The IRS requirement exists regardless of your UK tax position. But it's worth talking to a UK accountant if you're extracting significant income from a US LLC, because HMRC and the IRS treat the same entity differently.

Frequently asked questions

Do I have to file Form 5472 if my Wyoming LLC made no money?

Almost certainly yes, if you funded it at all. The initial capital you put in — even £200 to open a bank account — is a reportable transaction. The only scenario where you genuinely have no filing obligation is a year in which there were zero transactions between you and the LLC in either direction. Most dormant LLCs still have at least a bank account opened with some initial deposit.

My LLC has a UK bank account as well as a US account. Does that change anything?

No. It doesn't matter where the LLC's accounts are held. What matters is whether there were transactions between you (as the foreign owner) and the LLC. A UK account held by the LLC is still the LLC's account — transfers between it and your personal UK account are still reportable.

I missed the deadline. Can I still file?

Yes. File as soon as possible under the DIIRSP procedure. You attach a reasonable cause statement to the late return explaining why you didn't file on time — common reasons include not being aware of the requirement, which the IRS does accept in appropriate circumstances. The earlier you file, the better: the continuation penalties (§6038A(d)(2)) only start accruing after the IRS sends a notice.

Do I need a US EIN to file?

Yes. Your LLC must have an Employer Identification Number (EIN) to file Form 5472 and the pro forma 1120. If you don't have one yet, you need to apply before filing. Foreign owners typically apply by fax or by calling the IRS international line.

Do I need a US address for the LLC?

The LLC must have a US address on its formation documents and on the pro forma Form 1120. Most UK owners use a registered agent address in Wyoming or Delaware for this purpose.

Last reviewed: May 2026

Disclaimer: This post is general information about IRS filing obligations, not tax advice for your specific situation. Rules can change — always verify current requirements at irs.gov/instructions/i5472 or consult a qualified preparer before filing.