Form 5472


Form 5472, officially titled the Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business, is an IRS tax form used by foreign-owned United States companies or foreign companies engaged in a United States Trade or Business to report ownership information and related-party transactions between the company and foreign related parties.

History

Reporting requirements for foreign-owned domestic corporations were introduced with the Tax Equity and Fiscal Responsibility Act of 1982. In 1985, the IRS published the first version of Form 5472.
In 2017, the Treasury issued new regulations requiring foreign-owned disregarded entities, often single-member LLCs, to file Form 5472, due to concerns about limited federal visibility into these companies.

Foreign-owned disregarded entities

Although foreign-owned disregarded entities do not have any U.S. income tax liability, they are required to attach their Form 5472 returns to a pro forma corporate tax return, where only basic information is completed. They must report basic company information, ownership information, and information about the foreign related party and any transactions between them and the entity.
It is not possible to e-file a pro forma 1120 return; instead, foreign-owned disregarded entities are required to fax or mail their returns to a special IRS processing facility in Ogden, Utah.

Tax software

UltraTax CS and CCH Axcess Tax both support generating Form 5472 returns. TaxAct 1120 software also supports 5472 returns, but it doesn't support generating Form 5472 worksheets or pro forma 1120 returns for foreign-owned DEs.