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Form 5472 for a foreign-owned single-member LLC: what to report and how to file

Updated 11 November 2026

Draft: awaiting review by a practising accountant.

This guide explains general rules for orientation. It is not tax or legal advice; rules change and your facts matter. Check with a qualified accountant before you file.

Form 5472 is an information return. It reports transactions between a US company and its foreign related parties; it does not compute any tax. For a single-member LLC owned by someone outside the US, the related party is almost always you, the owner.

This page covers what to put on the form. For why the LLC has to file at all, what records to keep and a year-end checklist, see the pillar guide, Bookkeeping for a foreign-owned single-member US LLC.

Reportable transactions

For a foreign-owned disregarded entity (DE), the instructions and regulations define two groups.

Part IV: monetary transactions

Transactions with a related party where money is the only consideration. The categories that come up for a small software LLC:

Situation Part IV entry
The LLC pays your other company for development or design work Amounts paid for services
The LLC pays licence fees or royalties for code or a brand you own personally Royalties paid
You lend money to the LLC Amounts borrowed (line 17), with beginning and ending balances, or the monthly average
The LLC lends money to you Amounts loaned (line 31), same balance rules
Interest on those loans Interest paid or received (interest paid is line 32)
Other payments to or from you that fit no other line Other amounts paid (line 35) or received (line 21)

Part V: other transactions of a foreign-owned DE

Part V exists only for foreign-owned DEs. You check the box and attach a statement describing “any other transaction, as defined by Regulations section 1.482-1(i)(7)”, which the instructions say includes “amounts paid or received in connection with the formation, dissolution, acquisition, and disposition of the entity, including contributions to, and distributions from, the entity.”

In practice:

What happened Treated as Notes
You paid Stripe Atlas, Firstbase, doola, a state fee or a registered agent with a personal card Contribution Usually in the year the LLC was formed, so the first year almost always has something to report
You transferred money from a personal account to the LLC account Contribution Including the deposit that opened the account
You paid an LLC subscription, domain or contractor from a personal account Contribution, unless documented as a loan Keep the receipt
The LLC transferred money to your personal account Distribution Regardless of the transfer reference (“salary”, “payout”, “owner draw”)
The LLC paid one of your personal costs directly Distribution Better avoided: it mixes the books
The LLC is dissolved and the remaining cash goes to you Distribution in the final year The final year needs a Form 5472 too

Part VI: transactions without full consideration

If anything moves between you and the LLC for less than full value, or for something other than money (for example, you contribute code or equipment), it goes in Part VI with a schedule describing what moved and a reasonable estimate of its value. Most small software LLCs have nothing here, but transferring a pre-existing codebase or domain into a new LLC is a common exception.

What is not reportable

Transactions with unrelated customers, suppliers and platforms. Payouts from Stripe, Lemon Squeezy or Paddle to the LLC’s account are not related-party transactions. If such a payout lands in your personal account instead, the next transfer of that money to or from the LLC is.

Collecting the transactions from a year of statements

Most owners do not keep a running list, so the job at year end is to rebuild it from statements. A method that does not miss things:

  1. Gather every statement for the year: each LLC account, and each personal account or card you used to fund the LLC, receive money from it or pay its expenses. Check that each statement’s opening balance matches the previous closing balance, so you know none is missing.
  2. Find transfers between your own accounts. Each one shows up twice: an outflow on one statement and an inflow on the other, often days apart and in different currencies. Pair them into single events.
  3. Keep only the pairs where one side is the LLC and the other is you. Label each: contribution, distribution, loan, loan repayment.
  4. Scan personal card and account statements for LLC expenses: software subscriptions, domains, filing fees, contractors. Each one is an expense paid on behalf.
  5. Convert to US dollars. Use the dollar amount that actually arrived where you have it. Otherwise use one documented rate source, and list the rates in the schedule the instructions require.
  6. Total by type and keep the itemised list. The form carries totals; the itemised list and the statements are your records if the IRS asks.

The Form 5472 checker gives examples of reportable items for your situation, which is a useful prompt when you scan the statements.

How to file

A foreign-owned DE files Form 5472 attached to a pro forma Form 1120. Under the December 2024 instructions:

  • Pro forma 1120. Complete only the name and address of the LLC and items B (EIN) and E on page 1. Write “Foreign-owned U.S. DE” across the top.
  • Form 5472. Check the box on line 3 of Part I for a foreign-owned US DE. Check line 1j if this is the first year the LLC files Form 5472. Report yourself as the foreign owner in Part II, and complete Part III as well, even though it names the same person.
  • Identifiers. The LLC enters its EIN. For you: an SSN or ITIN if you have one; otherwise a reference ID number, alphanumeric, up to 50 characters, no spaces or special characters, used consistently every year. Enter your foreign tax identification number, or “None” or “N/A”.
  • Statements. The Part V statement, and a schedule of exchange rates if you converted any amounts.
  • Tax year. The LLC uses the tax year its owner uses for US filing, or the calendar year if the owner has no US filing.

Fax or mail, not e-file

Foreign-owned DEs cannot e-file Form 5472. The instructions give a dedicated route:

  • Fax: 855-887-7737, at 300 DPI or higher.
  • Mail: Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201.

Do not use the mailing addresses in the Form 1120 instructions. Keep the fax transmission report or a tracked mail receipt; it is your proof of timely filing.

The IRS “About Form 5472” page listed no recent developments when checked in November 2026, and the instructions in force are the December 2024 revision. Some commercial sites have reported 2026 changes to Form 5472; we could not find any in an official IRS source. Check the instructions page again before you file.

Deadline and extension

For a calendar-year LLC, the filing is due April 15 of the following year: April 15, 2027 for tax year 2026. Form 7004 extends it six months, to October 15, 2027. For a foreign-owned DE, Form 7004 goes to the same fax number or address as the return, not to the usual Form 7004 address, and must be sent by the original due date. Write “Foreign-owned U.S. DE” on it and use the Form 1120 code on line 1.

Common mistakes

  • Not filing because the LLC had no income. The trigger is related-party transactions, not profit. A first year with formation fees and a funded bank account is reportable.
  • Leaving out contributions and distributions. They are the most common transactions for a small LLC and the ones Part V exists for.
  • Forgetting expenses paid from personal cards. They are easy to miss because they never touch the LLC’s statements.
  • E-filing, or sending to the wrong address. Software may let you prepare a Form 1120 electronically; a foreign-owned DE’s filing still goes by fax or mail to the Ogden unit.
  • A new reference ID every year. It must stay the same from year to year.
  • Mixing currencies. Reporting the euro or yuan figure, or converting without stating the rates.
  • Skipping the final year. The year the LLC is dissolved, distributions of what is left are reportable.
  • Assuming this is the only filing. State annual reports and franchise taxes, and your own income tax returns in the US and at home, are separate.

How Selfirm helps

Selfirm reads a folder of bank and broker statements at once (PDF, XLSX or CSV), checks each statement’s balance chain so you know none is missing, pairs transfers between your own accounts and classifies every movement as income, expense or transfer for you to confirm. Each figure links back to the row in the original file, so the owner↔LLC transactions for Form 5472 come with their evidence. It does not prepare or file the form.

Common questions

Is the money I put into my LLC a reportable transaction?

Yes. For a foreign-owned disregarded LLC, contributions to the entity and distributions from it are reportable under Treas. Reg. §1.6038A-2(b)(3)(xi). They go in Part V of Form 5472, described on an attached statement.

I paid an LLC expense with my personal card. Do I report it?

Yes. Money you spend on the LLC's behalf is a transfer of value from you to the LLC, usually a contribution unless you documented it as a loan. Record each one with its receipt and include it in the year's totals.

Do I need an ITIN to file Form 5472?

No. If you have no SSN or ITIN, you enter a reference ID number instead: an alphanumeric identifier of up to 50 characters, no spaces or special characters, that you keep using every year. The LLC itself needs an EIN.

Can I report small amounts without exact figures?

The instructions allow a transaction or series of transactions totalling $50,000 or less to be reported as "$50,000 or less", and accept reasonable estimates between 75% and 125% of the actual amount when the actual amount cannot be determined. Exact figures from your statements are better when you have them.

Does a late Form 5472 still trigger the $25,000 penalty?

The penalty applies to a failure to file when due and in the prescribed manner, so a late filing is within its scope. A substantially incomplete form also counts as a failure to file. Talk to an accountant before filing a late year.

Sources

  1. IRS: Instructions for Form 5472 (Rev. December 2024)
  2. IRS: About Form 5472
  3. Treas. Reg. §1.6038A-1: General requirements and definitions
  4. Treas. Reg. §1.6038A-2: Requirement of return
  5. IRS: Instructions for Form 7004

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