Foreign-owned U.S. disregarded entities may have a Form 5472 filing obligation when reportable transactions occur. The form is generally attached to a pro forma Form 1120, and a missed or substantially incomplete filing can trigger a $25,000 penalty.
The reminder
If a foreign person directly or indirectly owns 100% of a U.S. disregarded entity, review the year's transactions before the filing deadline. Contributions, distributions and other transactions with the foreign owner or related parties can be reportable.
Do not assume that every foreign-owned single-member LLC files Form 5472 automatically in every year. The obligation depends on the entity's status and whether a reportable transaction occurred.
Get the full picture
Our evergreen Form 5472 guide explains the filing framework in more detail. Confirm the current IRS instructions for the tax year and seek qualified tax advice for your facts.