Foreign-owned single-member LLCs
A U.S. LLC owned by one non-U.S. person is a disregarded entity that must file a pro forma Form 1120 with Form 5472 — even with zero income.
Specialized Filing
Form 5472 Filing Help
If you are a non-U.S. person who owns a U.S. LLC or corporation, Form 5472 is probably required — and the penalty for getting it wrong is $25,000 per form, assessed automatically whether or not the business made a dollar. A foreign-owned single-member LLC must file even with zero income.
As an international tax specialist, I prepare Form 5472 together with the underlying 1120 (pro forma or full) so your reportable transactions are complete, consistent, and defensible.
Who This Applies To
25%+ foreign-owned U.S. corporations
A U.S. corporation that is at least 25% foreign-owned files Form 5472 for its reportable transactions with related parties.
Any reportable transaction
Capital contributions, loans, sales, service payments, rent, and property transfers between the entity and its foreign owner all count.
Missed or incomplete filers
A late or substantially incomplete 5472 carries the same penalty as not filing — the correction path matters.
What I Do
Form 5472 is short but unforgiving — the penalty is automatic and does not depend on how much money moved. I make sure it is complete and consistent.
- Confirm filing status: disregarded LLC pro forma 1120, or 25%+ owned corporation
- Identify and classify every reportable transaction with related parties
- Prepare Form 5472 and the associated 1120 (pro forma or full)
- Reconcile the recordkeeping that IRC 6038A requires you to maintain
- Build a reasonable-cause correction path when prior years were missed
Full Return, Handled End-to-End: For a foreign-owned LLC I handle the whole federal filing — the pro forma 1120, the 5472, and any related international forms — on one timeline.
Penalty Awareness — Form 5472 Exposure
Failure to File
$25,000
Per form, per year, under IRC 6038A — assessed automatically, regardless of income or tax due.
Continued Failure
+$25,000
An additional $25,000 for each 30-day period once 90 days pass after IRS notice. There is no statutory cap.
Zero-Income LLCs
Still Required
A foreign-owned single-member LLC must file a pro forma 1120 with Form 5472 even with no U.S. income or activity.
Recordkeeping
Required
Failing to keep the records that support reportable transactions triggers the same $25,000 penalty.
Form 5472 is one of the easiest penalties to trigger by accident and one of the largest for its size. If a year was missed, a documented reasonable-cause correction is the first move.
Form 5472 Questions
Form 5472 FAQ
Who has to file Form 5472?
Two groups: a U.S. corporation that is at least 25% owned by a foreign person and has reportable transactions with related parties, and a U.S. single-member LLC owned by a foreign person (a disregarded entity), which files Form 5472 attached to a pro forma Form 1120.
My foreign-owned LLC had no income. Do I still file?
Yes. A foreign-owned single-member LLC is treated as a disregarded entity for this purpose and must file a pro forma Form 1120 with Form 5472 whenever there is a reportable transaction — and forming the LLC, contributing capital, or paying its expenses all count. Zero income does not remove the obligation.
What is a reportable transaction?
Almost any exchange of money or property between the entity and a related foreign party: capital contributions, loans and repayments, sales and purchases, rent, royalties, interest, service payments, and property transfers. Even moving your own money into the LLC is reportable.
What is the penalty for not filing?
$25,000 per Form 5472 per year under IRC 6038A, assessed automatically and not based on tax owed. If the failure continues more than 90 days after the IRS sends notice, another $25,000 applies for each 30-day period, with no statutory maximum. The same penalty applies to filing a substantially incomplete form or failing to keep required records.
I missed Form 5472 for a prior year. What now?
You file the delinquent form with the associated 1120 and, in most cases, attach a reasonable-cause statement explaining why it was late. Well-documented reasonable cause can abate the penalty when there was no willful neglect. Acting before the IRS assesses the penalty gives you the strongest position.
What is the deadline?
Form 5472 is due with the entity return. For a foreign-owned single-member LLC filing a pro forma 1120, it is generally due April 15, with a six-month extension available to October 15. The form is filed by mail or fax, not through the normal e-file channel for a disregarded LLC.
About Your Preparer
Prepared Personally by Tajma Qorri
Tajma Qorri is the founder of Qorri Tax Service LLC and an international tax specialist with more than 10 years in public accounting at Plante Moran, Grant Thornton, and Dean Dorton. Her focus is cross-border compliance — Forms 5471, 5472, 3520, and 8938; FBAR reporting; streamlined filing procedures; and tax-treaty analysis — for individuals and small businesses.
Every engagement is handled directly by Tajma, never passed to junior staff, and she has filed returns for clients in all 50 states. You get a firm, flat-fee quote before any work begins.
Form 5472 Help in Chicago and Nationwide
Qorri Tax works from an office at 222 S Prospect Ave in Park Ridge, IL, serving Chicago-area clients in person and clients in all 50 states remotely. Whether you are around the corner or across the country, Form 5472 preparation is handled the same way — directly by Tajma, start to finish.
Form 5472 engagements are quoted as a flat fee up front, based on entity type and the number of reportable transactions. See pricing →
Need help with this filing?
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