US LLC Owned From the UAE: What Each Structure Files
Summary
However a UAE founder holds a US single-member LLC, personally or through a UAE company, it files Form 5472 with a pro forma 1120 each April 15. What changes is who counts as a related party.
Since the UAE introduced federal corporate tax, many founders have asked whether their US LLC's filing changed with it. It did not. What decides the US filing is how the LLC is held, and UAE founders hold it in one of three ways.
The three structures, and what each one files
| The US LLC is owned by | What the US LLC files each April 15 | Its foreign related parties |
|---|---|---|
| You, personally | Pro forma Form 1120 with Form 5472 | You |
| Your free zone company | Pro forma Form 1120 with Form 5472 | The free zone company, and you if you deal with the LLC directly |
| Your mainland company | Pro forma Form 1120 with Form 5472 | The mainland company, and you if you deal with the LLC directly |
In all three rows the US return is the same: a single-member LLC with one foreign owner is treated as a corporation for this reporting under Treas. Reg. §301.7701-2(c)(2)(vi), whether that owner is a person or a company. The difference is in the last column, who counts as a related party, because each foreign related party that transacts with the LLC in a year needs its own Form 5472.
Held personally
The simplest case. The LLC reports the money you put in, the money it pays you, and anything you pay on its behalf. One Form 5472 a year.
Held through a free zone company
The free zone company is the owner, so money moving between the LLC and that company is reportable. If you, the individual behind it, also pay the LLC's fees from a personal card or receive payments from the LLC directly, you are a second related party, and the year needs a second Form 5472. Many founders move money through whichever account is convenient; for this filing, the account matters.
Held through a mainland company
The same as a free zone company for the US filing. The UAE distinction between free zone and mainland affects UAE corporate tax, not the IRS.
What UAE corporate tax changed, and what it did not
For financial years starting on or after June 1, 2023, UAE companies pay federal corporate tax at 0% on taxable income up to AED 375,000 and 9% above it, with free zone companies able to qualify for 0% on qualifying income. An individual running a business personally is in scope only above AED 1 million of turnover.
None of that reaches the US LLC's filing. Form 5472 is an information return: it reports transactions, it computes no tax, and it is required whatever the owner's home tax rate is. A 0% UAE position, for a person or a company, does not remove it.
How the UAE treats the LLC's profits in your UAE company's own return is a question for your UAE tax adviser, and outside this page.
There is no treaty to fall back on
The US and the UAE have no comprehensive income tax treaty. For most filings that matters; for this one it does not, because no treaty removes an information return in the first place. What it does mean is that nothing in a treaty changes the analysis above.
A Dubai example, in dirhams
Omar holds a free zone company in Dubai that sells design templates. In March 2025 the free zone company formed a Wyoming LLC to sell to US customers. During 2025:
- The free zone company transferred AED 36,725 (about $10,000) to the LLC's US bank account to start it.
- Omar paid the LLC's registered agent fee, $125, from his personal card.
- The LLC paid the free zone company $40,000 of its profits in December.
The 2025 return, due April 15, 2026, needs two Forms 5472: one for the free zone company, reporting the $10,000 in and the $40,000 out, and one for Omar, reporting the $125 fee he paid. Had the fee been paid from the company's account, one form would have been enough.
That second form is the most common thing UAE structures miss. The penalty for a missing Form 5472 is $25,000 per form under IRC §6038A(d)(1), so it is worth deciding which account pays the LLC's costs before the year starts.
How UAE founders usually find out
Usually through the US bank or payment platform. A compliance review asks for the LLC's filed US returns, often a year or two after formation. If that is how you arrived here and years are open, the missed Form 5472 page sets out how to catch up. What each line of the form needs is in the Form 5472 guide.
If the LLC has one foreign owner and ordinary transactions with it, FileTax prepares the Form 5472 and pro forma Form 1120 packet in under 15 minutes for $99 per year, plus $25 for each additional related party's Form 5472.
Questions UAE owners ask
My UAE company pays 0% tax. Does the US LLC still file?
Yes. The US filing is an information return about transactions between the LLC and its foreign owner. It applies whatever tax rate the owner pays at home.
Is there a US-UAE tax treaty?
There is no comprehensive income tax treaty between the two countries. It would not remove the Form 5472 filing even if there were.
Does it matter whether my UAE company is free zone or mainland?
Not for the US filing. Both are foreign companies owning a US LLC, and the LLC files the same way.
My company owns the LLC but I sometimes pay its bills personally. Is that a problem?
It means you are a second related party that year, and the return needs a second Form 5472 for you. Paying the LLC's costs from the owning company's account keeps it to one.
Related pages
Continue reading
Form 5472: The Complete Guide for Foreign-Owned US LLCs →
A foreign-owned US single-member LLC files Form 5472 with a pro forma Form 1120 by April 15. Funding the LLC is itself reportable. Missing it costs $25,000 per form, per year.
Reportable Transactions on Form 5472: 18 Common Ones, Yes or No →
Funding the LLC, paying its fees yourself, loans and distributions are all reportable. Customer payments, suppliers and moving money between the LLC's own accounts are not.
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.