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

Form 5472 EssentialsOctober 29, 2026

US LLC Owned by a Foreign Company: Direct Owner, Ultimate Owner, and Form 5472

Summary

A US single-member LLC owned by a foreign company still files Form 5472 with a pro forma 1120. Part II names both the company that owns it directly and the person who owns that company.

Many founders do not own their US LLC personally. Their company at home does: a GmbH in Germany, a private limited company in India, a free zone company in Dubai. The LLC's yearly filing is the same Form 5472 with a pro forma Form 1120, but three things about it change.

Part II names two owners, not one

Part II of Form 5472 identifies the LLC's 25% foreign shareholder. When a company owns the LLC, that is the company: the direct owner. The form also asks about the ultimate owner, the person or company at the top of the chain.

The instructions are specific: a foreign-owned US disregarded entity must enter a foreign taxpayer identification number for each direct and ultimate foreign owner listed in Part II, if they have one. So the filing needs your company's tax number from its home country and, as the ultimate owner, yours.

Each foreign related party that transacts with the LLC in a year gets its own Form 5472. With a company in the middle, the usual candidates are:

  • the owning company, for money it puts in, takes out, or charges;
  • you personally, if you pay any LLC cost from your own card or receive anything directly;
  • sister companies under the same ownership that sell to, buy from or lend to the LLC.

Keeping all money flowing between the LLC and the owning company, and nothing through you personally, keeps it to one form.

Pricing between the companies matters

When the LLC buys from or sells to its owner's company, or pays it for services or management, the IRS expects the price to be what unrelated parties would agree. For small, simple flows this is rarely an issue. For regular trading between the companies it is transfer pricing, and a qualified CPA should look at it.

A German example

Nordlicht GmbH, a software company in Hamburg owned by Lena, formed a Delaware LLC in 2025 to sell to US customers.

  • February 2025: the GmbH transferred $20,000 to the LLC to start it.
  • Monthly: the LLC paid the GmbH $4,000 for development work, $44,000 across the year.
  • Once: Lena paid the LLC's registered agent fee, $150, from her personal card.
  • December 2025: the LLC paid the GmbH $30,000 of profit.

The 2025 filing is one pro forma Form 1120 with two Forms 5472:

Form 5472 forReportsWhere on the form
Nordlicht GmbHThe $20,000 contribution and $30,000 distributionPart V statement
Nordlicht GmbHThe $44,000 paid for development servicesPart IV
LenaThe $150 fee she paid for the LLCPart V statement

Part II on both names the GmbH as direct owner and Lena as ultimate owner, with the GmbH's German tax number and Lena's.

The development fees are exactly the kind of related-company pricing that should be reviewed by a qualified CPA.

One thing that does not change

The responsible party for the LLC's EIN must still be an individual, not a company. On Form SS-4, that is the person who ultimately controls the LLC, here Lena. The EIN without an SSN page covers the form.

When to get help

A company-owned LLC with only contributions and distributions to its parent is simple. Add service fees, goods, loans between affiliates or more than one layer of ownership, and it is outside what an automated tool should prepare; the when Form 5472 is not your only problem page lists similar setups. FileTax prepares the simple case for $99 per year, plus $25 per additional related party's form.

Questions about company-owned LLCs

Is a US LLC owned by a foreign company still a disregarded entity?

Yes, if it has one owner and has not elected otherwise. For Form 5472 purposes it is treated as a corporation, and it files the pro forma Form 1120 like any foreign-owned single-member LLC.

The company, for everything it does with the LLC. You too, if you deal with the LLC directly. Each needs its own form.

Do I need my company's foreign tax number?

Yes. A foreign-owned DE must enter the foreign tax number of each direct and ultimate foreign owner listed in Part II.

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