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A foreign-owned US single-member LLC with any reportable transaction during the year must file Form 5472 with a pro forma Form 1120, due April 15 for a calendar-year LLC.
Question 1
General information, not personalised tax planning. For advice on your own situation, speak to a tax professional.
The rule in plain English
The common Form 5472 case is a US single-member LLC that is wholly owned by a non-US person or foreign company and has not elected corporate tax treatment. The IRS treats that LLC as a disregarded entity for income tax purposes, but still requires an information filing when reportable transactions occur. If the LLC is not formed yet, see can a foreigner own a US LLC.
Reportable transactions are broader than sales revenue. Owner capital contributions, loans, reimbursements, formation costs paid personally, registered-agent fees paid by the owner, and owner draws can all matter even when the LLC had no customers and no profit.
Some paths are different. A multi-member LLC usually starts with partnership filing rules, and an LLC that elected to be taxed as a corporation files through its corporate Form 1120 process. This checker separates those cases so the answer is not forced into a filing sale when the facts point elsewhere.
Generally, a “reporting corporation” that had a reportable transaction with a foreign or domestic related party must file Form 5472. The IRS defines a reporting corporation as a 25% foreign-owned US corporation, including a foreign-owned US disregarded entity, or a foreign corporation engaged in a trade or business within the United States.
That covers three kinds of filer:
A reporting corporation does not file for a year with no reportable transactions of the types listed in Parts IV and VI of the form, and, for a foreign-owned US disregarded entity, Part V. Several other exceptions in the instructions, such as the Form 5471 exception, do not apply to foreign-owned US disregarded entities.
A reporting corporation files a separate Form 5472 for each related party it had reportable transactions with, attached to its income tax return by that return’s due date, including extensions. A foreign-owned US disregarded entity attaches Form 5472 to a pro forma Form 1120 and must fax or mail it; it cannot e-file.
For a part-by-part walkthrough, read our Form 5472 instructions guide.
How we decide
Each question applies one rule from the primary sources below. Where you answer “Not sure” about money moving, the checker leans towards filing; that is our cautious choice, not an IRS rule.
A U.S. LLC wholly owned by one foreign person is disregarded for income tax, but the regulations treat it as a corporation for section 6038A, which makes it a “reporting corporation”. A reporting corporation must file Form 5472 if it had a reportable transaction with a related party, and a foreign-owned LLC files it attached to a pro forma Form 1120.
By default a U.S. LLC with two or more members is a partnership, and one with a single owner is disregarded. Partnerships file Form 1065, so a multi-member LLC gets the “different rules” result. The pro forma Form 1120 route is written for the single-owner case.
The disregarded-entity rule applies when one foreign person owns the LLC. A single-member LLC owned by a U.S. person isn't covered by it, so the checker shows no Form 5472 filing.
An LLC that elected to be taxed as a corporation files its own corporate income tax return. If it is at least 25% foreign-owned it is a reporting corporation and attaches Form 5472 to that return, so the filing path differs. “Not sure” is treated as no election, because the default classification applies unless the LLC elected otherwise.
Form 5472 reports transactions during the reporting corporation’s tax year, so the checker asks whether the LLC existed at any point in the year. A foreign-owned LLC uses its owner’s U.S. tax year or, if the owner has none, the calendar year.
For a foreign-owned LLC, reportable transactions include amounts paid or received in connection with forming, dissolving, acquiring or disposing of the LLC, including contributions to and distributions from it, as well as payments such as loans listed in Part IV of the form. No income is not the same as no transactions. The instructions excuse a year with no reportable transactions.
The pro forma Form 1120 is due by the 15th day of the 4th month after the tax year ends (April 15 for a calendar year), or later with a timely Form 7004. Not filing Form 5472 when due, or filing a substantially incomplete one, carries a $25,000 penalty.
Last reviewed 29 September 2026 against the Form 5472 instructions (Rev. 12/2024), the Form 1120 and Form 1065 instructions, IRC §6038A and the Treasury regulations linked above. General information, not tax advice.
A foreign-owned US single-member LLC that is treated as a disregarded entity usually files Form 5472 with a pro forma Form 1120 when it has a reportable transaction during the tax year.
Often, yes. No income is different from no reportable transactions, and formation costs, owner contributions, reimbursements, loans, or owner draws can create a filing requirement.
For a calendar-year LLC, Form 5472 with the pro forma Form 1120 is generally due April 15. Extensions may be available, but the extension process must be handled correctly.
The penalty is $25,000 for a Form 5472 that is not filed when due or is substantially incomplete. Late filings can sometimes include a reasonable cause explanation, but the best answer depends on the exact facts.
If the checker points to a filing requirement, Form5472 Prep prepares Form 5472 and the pro forma 1120 for your foreign-owned LLC.
Before you order, see what a Form 5472 preparer does and what you hand over when you hire someone to file Form 5472.
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