Pro Forma Form 1120 for a Foreign-Owned LLC

A pro forma Form 1120 is the abbreviated cover return that a wholly foreign-owned US disregarded entity uses to transmit Form 5472. It does not automatically turn the LLC into a corporation for all federal income-tax purposes. The filer completes the limited identifying items required by the instructions, writes "Foreign-owned U.S. DE" across the top, and attaches Form 5472.

The pro forma return and Form 5472 form one IRS package. The mistake is treating the pro forma 1120 like a corporate return. A foreign-owned disregarded LLC is using Form 1120 as a filing envelope, not reporting corporate taxable income by default. Missing the package can trigger the $25,000 penalty under IRC §6038A(d).

The IRS Form 5472 instructions say that a foreign-owned U.S. disregarded entity files a pro forma Form 1120 with Form 5472 attached and that the only information required on Form 1120 is the name and address of the foreign-owned U.S. DE plus items B and E on the first page (IRS Form 5472 instructions). If you want the full package prepared consistently, start the guided package.

Why does a disregarded LLC use Form 1120?

A foreign-owned disregarded LLC uses Form 1120 because the section 6038A reporting regulations treat the LLC as separate from its owner only for a limited information-reporting purpose. The pro forma Form 1120 is the cover return that lets Form 5472 be filed.

The IRS Form 5472 instructions define a foreign-owned U.S. DE as a domestic disregarded entity wholly owned by a foreign person. For tax years beginning on or after 1 January 2017 and ending on or after 13 December 2017, the instructions say that foreign-owned U.S. DE is treated as separate from its owner and classified as a corporation for the limited purposes of the section 6038A requirements (IRS Form 5472 instructions).

That rule creates the filing package:

Document	Role in the package	What it does not do
Pro forma Form 1120	Identifies the foreign-owned U.S. DE and acts as the return wrapper	Does not make the LLC a C corporation by itself
Form 5472	Reports the owner, related parties and reportable transactions	Does not calculate income tax
Part V statement	Describes disregarded-entity transactions such as formation, contributions, distributions or dissolution	Does not replace the form itself
Fax or mailing proof	Shows delivery to the IRS Ogden PIN Unit	Does not guarantee IRS acceptance

The pro forma 1120 matters because Form 5472 is attached to it.

Is the pro forma Form 1120 a full corporate return?

No. The pro forma Form 1120 for a foreign-owned disregarded entity is not a full corporate income-tax return. The IRS Form 5472 instructions limit the Form 1120 information required for this specific package to the entity's name and address, item B, and item E on page 1.

That corrects a common overfilling error. Ordinary Form 1120 instructions discuss many corporate return lines and schedules. A foreign-owned U.S. DE pro forma package does not automatically complete those sections.

Item	Pro forma 1120 for foreign-owned DE	Full Form 1120 corporate return
Purpose	Transmit Form 5472 under section 6038A	Report corporate income tax
Entity status	LLC remains disregarded except for limited reporting rule	Entity is taxed as a corporation
Required Form 1120 fields for this package	Name, address, item B and item E	Applicable income, deductions, tax, schedules and signature fields
Income lines	Generally not completed for the DE pro forma package	Completed when a corporation reports income tax
Filing method for this package	Fax or mail to the Ogden PIN Unit	Ordinary corporate-return filing rules

The Form 1120 instructions identify item B as the employer identification number and say a corporation without an EIN must apply for one (IRS Form 1120 instructions). The same instructions describe item E as the initial return, final return, name change or address change boxes.

Which boxes and lines does the foreign-owned DE actually complete?

A foreign-owned disregarded entity completing the Form 5472 pro forma package completes the LLC's name and address, item B, and item E on Form 1120 page 1. The form should also have "Foreign-owned U.S. DE" written across the top.

Use this decision framework:

Name and address: enter the U.S. LLC's legal name and mailing address. Do not replace the LLC name with the foreign owner's personal name.
Item B, Employer Identification Number: enter the LLC's EIN. If the LLC does not have an EIN, obtain one before filing.
Item E, Initial return: check if this is the LLC's first pro forma Form 1120 package.
Item E, Final return: check if this is the final package and the entity will no longer exist.
Item E, Name change: check if the LLC's legal name changed.
Item E, Address change: check if the LLC's address changed.
Top notation: write "Foreign-owned U.S. DE" across the top of Form 1120.
Attachment: attach Form 5472 and the required supporting statements.

Do not add random zeroes across income, deductions, balance sheet or tax-computation lines. A blank field is cleaner than an invented corporate return.

What information goes on Form 5472 instead?

Form 5472 carries the substance: entity classification, owner details, related-party identity and reportable transactions. The pro forma 1120 is intentionally thin because Form 5472 is the real information return.

For a foreign-owned U.S. DE, the IRS instructions say to check line 3 if the reporting corporation is a foreign-owned U.S. DE. The instructions also say only 25% foreign-owned U.S. corporations, including foreign-owned U.S. DEs, complete Part II, and that a foreign-owned U.S. DE reports the foreign owner on the lines provided for the 25% foreign shareholder (IRS Form 5472 instructions).

The federal package commonly includes:

Form 1120 page 1 with the limited pro forma information.
Form 5472 Part I for the reporting corporation details.
Form 5472 line 3 checked for foreign-owned U.S. DE status.
Form 5472 Part II for the foreign owner's information.
Form 5472 Part III when a related party is separately reportable.
Form 5472 Part IV, V or VI entries depending on transaction type.
A Part V attachment for formation, contribution, distribution, acquisition, disposition or dissolution transactions of the disregarded entity.
Optional schedules for exchange rates, ownership references or reasonable cause when filing late.

If the owner has no U.S. identifying number, Form 5472 requires a reference ID number in the applicable Part II lines when no U.S. identifying number is entered for the foreign shareholder (26 CFR §1.6038A-2).

How is the pro forma package filed?

The pro forma package is filed by fax or mail to the IRS Ogden PIN Unit. It is not e-filed through ordinary business tax software.

Follow this sequence:

Confirm the LLC was wholly foreign-owned and disregarded during the tax year.
Confirm at least one reportable transaction occurred, or document why none occurred.
Complete the limited Form 1120 page-one information: name, address, item B and item E.
Write "Foreign-owned U.S. DE" across the top of Form 1120.
Complete Form 5472 and the Part V statement.
Assemble one ordered package with Form 1120 first and Form 5472 attached.
Fax at 300 DPI or higher to 855-887-7737, or mail to the dedicated Ogden PIN Unit address listed in the Form 5472 instructions.
Save the exact filed package and delivery proof.

The IRS Form 5472 instructions say foreign-owned U.S. DEs must use the special mailing address, not ordinary Form 1120 mailing addresses, and cannot file electronically (IRS Form 5472 instructions).

For the 2025 tax year, a calendar-year package is generally due 15 April 2026. A timely Form 7004 can extend the filing deadline to 15 October 2026, but Form 7004 for this DE package must follow the same special foreign-owned U.S. DE fax or mail procedure described in the Form 5472 instructions.

What mistakes cause incomplete packages?

Incomplete pro forma packages usually fail because the filer either sends too little or invents too much. The narrow IRS instruction should drive the package.

Mistake	Why it is a problem	Better treatment
Sending Form 5472 without Form 1120	The foreign-owned DE files Form 5472 attached to a pro forma 1120	Put Form 1120 first
Filling every income line with zeroes	The DE pro forma instruction is limited	Complete only the required Form 1120 identifiers
Omitting "Foreign-owned U.S. DE"	The IRS instructions expressly call for the notation	Write it across the top
Using the owner's tax number as the LLC EIN	Item B belongs to the reporting entity	Use the LLC's EIN
Reporting only customer revenue	Form 5472 is about related-party transactions	Reconcile owner contributions, distributions, loans and reimbursements
Filing one Form 5472 for multiple related parties	The form is related-party specific	Prepare the needed Form 5472 set
Mailing to the ordinary Form 1120 address	The DE instructions require the dedicated Ogden route	Use the special fax or mailing address

Use the part-by-part Form 5472 guide to cross-check the attached information return before sending.

What does a worked pro forma package look like?

A worked example shows how little goes on Form 1120 and how much belongs on Form 5472.

Assume a foreign individual owns 100% of a Wyoming LLC. The owner formed the LLC in 2025, wired USD 1,200 into the LLC's bank account, and later withdrew USD 500. The LLC had no U.S. office, no U.S. employees and no U.S.-source income-tax position to report on a corporate return.

The pro forma Form 1120 page-one work is limited:

LLC legal name and address entered at the top.
LLC EIN entered in item B.
Item E "Initial return" checked if this is the first package.
"Foreign-owned U.S. DE" written across the top.
No invented corporate gross receipts, deductions or tax lines.

The Form 5472 work carries the numbers:

line 3 checked to identify foreign-owned U.S. DE status;
Part II completed for the foreign owner;
Part V statement showing the USD 1,200 contribution and USD 500 distribution; and
arithmetic in the workpaper: 1,200 contributed - 500 distributed = 700 net owner funding for the year.

The arithmetic does not mean only 700 is reportable. The contribution and distribution are separate transactions.

How does Form5472 Prep fit as the answer?

Form5472 Prep prepares the whole federal package: Form 5472, the pro forma Form 1120 and the Part V statement. A qualified tax accountant reviews the package before filing.

After signature, we fax the package to the IRS Ogden PIN Unit at 855-887-7737 and return the 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.

We are not a CPA firm and do not give tax advice. If the LLC still needs an EIN, the EIN service is $149 at /ein. If the Form 5472 package is ready, use the pro forma 1120 intake.

Frequently asked questions

Does filing a pro forma 1120 make the LLC a C corporation?

No. The LLC is treated as a corporation only for limited section 6038A reporting. A separate classification election is needed to make the LLC a corporation for income-tax purposes.

Does the pro forma Form 1120 report business profit?

Generally no for this package. The foreign-owned DE pro forma instruction requires limited page-one information, while Form 5472 reports related-party transactions.

Can the LLC file Form 5472 without Form 1120?

No. A covered foreign-owned U.S. disregarded entity attaches Form 5472 to the required pro forma Form 1120.

Which Form 1120 items are completed?

The IRS Form 5472 instructions require the foreign-owned U.S. DE's name and address plus items B and E on Form 1120 page 1.

Does the LLC need an EIN?

Yes. Item B is the employer identification number. The LLC uses its own EIN even when the foreign individual owner has no SSN or ITIN.

Can the pro forma package be e-filed?

No. The Form 5472 instructions say a foreign-owned U.S. DE cannot file Form 5472 electronically and must use the special fax or mail procedure.

What goes in the Part V statement?

The Part V statement describes disregarded-entity reportable transactions, such as formation, contributions, distributions, acquisitions, dispositions and dissolutions involving the foreign owner or related parties.

The pro forma 1120 is short, but not optional. Use IRS-limited fields, attach the Form 5472 detail, and keep delivery proof. Start the complete filing or review whether an ITIN is needed.