Form 5472

In full

IRS Form 5472 is required of every U.S. corporation that is at least 25% foreign-owned, and of foreign-owned single-member LLCs that are disregarded entities. It must be filed annually with a Pro-Forma 1120 reporting every reportable transaction with related parties — capital contributions, distributions, intercompany loans, services. The penalty for failure to file is $25,000 per form per year. While it stays unfiled, the clock the IRS normally runs against that year to assess tax never starts, so an unfiled year stays open rather than closing on the ordinary three-year cycle.

Governed by: Foreign-owner disclosure rules.

This definition is general information about how the term is used in U.S. cross-border tax. It is not advice, and how it applies depends on your own facts and on the treaty, if any, in force with your country.