⚠ IRS Warning

The IRS penalty for a missing Form 5472 starts at $25,000 per form per year. Every unfiled year adds another.

Form 5472 EssentialsMay 24, 2026

Form 5472 Instructions for a Foreign-Owned LLC, Part by Part

Summary

A single-member LLC with a foreign owner names the owner in Parts II and III, reports loans and payments for services in Part IV, and ticks Part V with a statement listing money put in and taken out.

FileTax article card: Every Line Explained. For owners filling in Form 5472 with the form open.

This page follows one filing from a blank form to a finished one: the 2025 Form 5472 for Harbor Loop LLC, a Wyoming LLC owned by Diego Ramírez, who lives in Mexico City. His 2025 dealings with the LLC were:

  • he put in $4,000 to open its bank account (March 3);
  • he paid $450 of its formation and registered agent fees from his own card;
  • he lent it $6,000 (June 10), and it repaid $6,000 (November 20);
  • it paid him $2,500 for design work he did for it;
  • it paid him $20,000 of its profit (December 15).

The filing requirement comes from IRC §6038A, and Treas. Reg. §1.6038A-2 defines which transactions count. Form 5472 (Rev. December 2023) has nine parts. The instructions tell a foreign-owned US disregarded entity which apply; for Diego's LLC, the work is in Parts I to V.

Part I: the reporting corporation

Part I describes the LLC itself.

  • 1a, name and address: Harbor Loop LLC and its address as the IRS has it.
  • 1b, EIN: the LLC's own EIN. The form cannot be filed without one.
  • 1c, total assets: the LLC's assets at year end, mainly its bank balance.
  • 1d and 1e, principal business activity and code: "Mobile app development" and the matching business code from the instructions.
  • 1f, total value of gross payments on this form: the total value of the payments made or received that this form reports, filled in last.
  • 1g, number of Forms 5472 filed: 1, because Diego is the only related party.
  • 1h, total across all Forms 5472: the same as 1f when there is one form.

Further down, Part I asks for the countries where the LLC does business and files, and has a checkbox that identifies the filer as a foreign-owned U.S. DE. Tick it. It is how the IRS knows which rules apply to the return.

Part II: the 25% foreign shareholder

Part II names the foreign owner, Diego, as the LLC's direct 25% foreign shareholder: his name, address, country of citizenship and country of tax residence.

His tax ID matters. The instructions say a foreign-owned US DE must enter a foreign taxpayer identification number, if the owner has one. Diego enters his Mexican RFC. Leaving it blank when a number exists makes the form incomplete.

If he has no US number (no SSN or ITIN), the US identifying number field stays empty and a reference ID number is used instead. The IRS rules for it are strict: letters and digits only, no spaces or special characters, up to 50 characters, and the same number every year. "HARBORLOOPDR01" works. "FRP-001-HarborLoop" does not, because of the hyphens.

Part III names the party the LLC actually dealt with. For a single owner dealing with his own LLC, that is Diego again. Tick the box describing the relationship (he is the 25% foreign shareholder) and repeat his identifying details.

If the LLC had also dealt with, say, his Mexican company, that company would be a second related party with its own Form 5472 and its own Part III.

Part IV: monetary transactions

Part IV is a list of transaction types with a dollar amount for each, split between money the LLC received and money it paid. A foreign-owned DE completes the lines that apply to it. For Diego's LLC:

  • Amounts borrowed: the $6,000 loan from Diego, with the year-end balance (nil, since it was repaid).
  • Amounts paid for services: the $2,500 paid to him for design work.

The repayment of the loan is reported on the loan lines as the instructions describe. Everything else Diego's LLC did with him is not a Part IV category, and goes to Part V.

Part V: the foreign-owned DE's other transactions

Part V is a single checkbox. Tick it if the LLC had any transaction with its related party that is not in Part IV, and describe those transactions on an attached statement. The instructions name the usual ones: amounts paid or received in connection with forming, dissolving, acquiring or disposing of the entity, including contributions and distributions.

Diego's statement lists:

  • Capital contribution from owner, March 3, 2025: $4,000
  • Formation and registered agent fees paid by owner on the LLC's behalf, 2025: $450
  • Distribution to owner, December 15, 2025: $20,000

Label the statement with the LLC's name, EIN and tax year, and a heading that ties it to Part V.

Parts VI to IX

  • Part VI covers nonmonetary transactions and transactions for less than full value, such as the owner giving the LLC equipment. Diego had none.
  • Part VII is a set of yes-or-no questions; for a small operating LLC like his the answers are generally no.
  • Part VIII concerns cost sharing arrangements, and Part IX base erosion payments under a regime aimed at large corporations. Neither applies to him.

Currency, and what goes with the form

Every amount is in US dollars. Where money moved in another currency, the instructions require a schedule showing the exchange rates used, attached to the return. Diego's transfers were in dollars on arrival, so his schedule is short, but it is still worth stating the source of any rate.

The Form 5472 is attached to a pro forma Form 1120 with "Foreign-owned U.S. DE" across the top; the pro forma 1120 page covers what goes on it. The packet goes to the IRS PIN Unit in Ogden by mail or fax, never e-file; the where to send page has the address. Which transactions count at all is set out on the reportable transactions page.

A single owner with transactions like Diego's is what FileTax is built for: it prepares the Form 5472, the Part V statement and the pro forma Form 1120 in under 15 minutes for $99 per year. More than one related party, property transferred in kind, or US business income calls for a qualified CPA review.

Questions about filling in Form 5472

Which parts does a foreign-owned single-member LLC complete?

Part I for the LLC, Part II for the foreign owner, Part III for the related party, Part IV for monetary transactions such as loans and payments for services, and Part V for other transactions such as contributions and distributions. Parts VI to IX are answered as they apply, which for a small LLC is usually none or no.

Do contributions and distributions go in Part IV or Part V?

Part V. The instructions list contributions to and distributions from the entity among the transactions a foreign-owned DE describes on the Part V statement.

What reference ID number should I use?

One you create, made only of letters and digits, no spaces or special characters, up to 50 characters, and used again every year for the same person.

My owner has a foreign tax number. Is it optional?

No. A foreign-owned DE must enter a foreign taxpayer identification number for its foreign owners if they have one.

Can I report in euros or rupees?

No. Every amount is in US dollars, with a schedule of the exchange rates used attached.

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