Firstbase LLC After the BOI Change: What Is Still Filed
Summary
The BOI report is gone for US-formed LLCs, including every Firstbase LLC, since March 26, 2025. The yearly IRS filing, Form 5472 with a pro forma Form 1120, was never part of that rule and continues.
What changed: Since March 26, 2025, an LLC formed in a US state no longer files a beneficial ownership information (BOI) report with FinCEN. Firstbase forms LLCs in US states, so no Firstbase LLC owes one, whoever owns it.
What did not change: A Firstbase LLC owned by one person living outside the US still files Form 5472 with a pro forma Form 1120 with the IRS every year, due April 15.
The two were easy to confuse because both arrived at once for many founders, and both were about ownership. They come from different laws, go to different agencies, and only one of them ended.
BOI and Form 5472, side by side
| BOI report | Form 5472 | |
|---|---|---|
| Sent to | FinCEN | IRS |
| Required of a US-formed LLC today | No, since March 26, 2025 | Yes, if foreign-owned with a reportable transaction |
| How often | Was a one-off report with updates | Every year |
| Due | No longer applies | April 15, or October 15 with Form 7004 |
The BOI rule was narrowed by a FinCEN interim final rule issued on March 21, 2025 and published on March 26, 2025. It now applies only to companies formed under foreign law and registered to do business in a US state. A Wyoming or Delaware LLC is formed under US state law, so it falls outside the rule. An owner living abroad does not bring it back in: the test is where the company was formed.
Form 5472 comes from IRC §6038A, which the BOI change did not touch.
If you already filed a BOI report
Nothing needs to be done with it. US-formed companies that reported before the change do not have to update or withdraw their reports.
If you never filed one because the deadlines kept moving in 2024 and early 2025, there is nothing to catch up on for BOI.
What a Firstbase LLC files now, by date
- April 15: Form 5472 and pro forma Form 1120 for the previous calendar year, sent by mail or fax to the IRS in Ogden, Utah. A Form 7004 sent by April 15 moves it to October 15; the deadline page has the details.
- The state's own date: the annual report or tax for the state of formation. A Wyoming LLC files its annual report by the first day of the month it was formed in; a Delaware LLC pays its annual tax by June 1, now $400. Delaware raised this from $300 to $400 in 2026 (House Bill 400), starting with the payment due June 1, 2027.
Firstbase handles the formation, and depending on your plan, some of the state items. If you pay for a compliance plan, read what it lists. If Form 5472 is not named in it, the federal filing is still yours. The formation services compared page shows the same gap across providers.
If the BOI news made you think the federal filings were over and a year or more has passed without a Form 5472, the missed Form 5472 page sets out how to catch up. The penalty for a missing return is $25,000 per form, per year.
FileTax prepares the Form 5472 and pro forma Form 1120 packet for a single-owner Firstbase LLC in under 15 minutes for $99 per year.
Related pages
Continue reading
LLC Formation Services and the Tax Filing They Leave Out →
Formation and compliance packages cover state registration and annual reports. None of them file Form 5472, the annual federal return a foreign-owned LLC owes with a $25,000 penalty.
US Tax Filing Requirements for Foreign-Owned LLCs →
A foreign-owned US LLC files Form 5472 with a pro forma 1120 by April 15, plus its state annual report. BOI reporting no longer applies. US income tax is usually zero.
Form 5472 Deadline: April 15, or October 15 With Form 7004 →
Form 5472 is due on the 15th day of the fourth month after the tax year ends: April 15 for almost every foreign-owned LLC. A Form 7004 sent by that date moves it to October 15.