How Many Years of Form 5472 Do I Owe? Count Them in Three Steps
Summary
Count from the LLC's formation year to the last year whose April 15 has passed, then remove any year with no transaction between you and the LLC. No year is too old to count.
Owners who find out late all ask the same thing: how far back do I go? The count takes three steps, and there is no cutoff for old years.
Step 1: start at the year the LLC was formed
The first tax year begins on the day the LLC was formed, even if that was December. A part-year counts as a full return.
Step 2: stop at the last year whose deadline has passed
A calendar-year LLC's return is due April 15 of the following year. As of October 2026:
| LLC formed in | Years already due | Count |
|---|---|---|
| 2020 | 2020, 2021, 2022, 2023, 2024, 2025 | 6 |
| 2022 | 2022, 2023, 2024, 2025 | 4 |
| 2024 | 2024, 2025 | 2 |
| 2025 | 2025 | 1 |
| 2026 | None yet; 2026 is due April 15, 2027 | 0 |
Step 3: drop any year with no transaction with you
A year needs Form 5472 only if the LLC had a reportable transaction with you or another foreign related party. Go through each year and ask: did money move between us, or did I pay anything for the LLC? A year where the answer is genuinely no may not need a return; the dormant LLC page explains how rare that is.
What is left is the number of returns you owe. Each is a separate Form 5472 and pro forma Form 1120, one set per year.
Why old years still count
It is natural to assume that very old years have lapsed. They have not. Under IRC §6501(c)(8), the time the IRS has to assess a year does not start until that year's Form 5472 is filed, so a 2020 return that was never sent is as open today as 2025. The statute of limitations page explains the rule.
What the count means
Every year on the list carries the same $25,000 penalty per missing form, which is why the list is filed all at once, with a single statement explaining why the returns were missed, rather than one year at a time. The multiple years late page follows a four-year catch-up from start to finish.
If more than one year is missing, you can file every missed year as one job, with one reasonable cause letter covering all of them.
FileTax prepares every year on your list as one job at $99 per year, with one CPA-authored reasonable cause letter covering all of them for $199.
Questions about counting the years
My LLC was formed in December. Does that month count as a year?
Yes. The part-year from formation to December 31 is the LLC's first tax year and has its own return if anything passed between you and the LLC.
Is there a limit to how far back I have to go?
No. An unfiled year stays open until its return is filed.
I filed some years but not others. Do I count those?
Count only the years with no return filed. Years already filed are done.
Related pages
Continue reading
Several Years of Form 5472 Late: One Catch-Up, Start to Finish →
Every open year gets its own Form 5472 and pro forma Form 1120, oldest first, all sent together under one reasonable cause statement. Filing only the latest year invites a question about the rest.
Statute of Limitations on Form 5472 - Why the IRS Clock Has Not Started Yet →
Foreign founders sometimes hope the statute of limitations will eventually close the door on unfiled Form 5472 years. It does not work that way. The clock has not started.
Form 5472 for a Dormant LLC: Does a Quiet Year Need a Return? →
A year needs no Form 5472 only if nothing passed between the LLC and its foreign owner or related parties. If you paid its state fee or agent renewal yourself, the year needs a return.