Printable Form 2026

IRS Form 5472 – IRS Form, Instructions, Pubs 2026

IRS Form 5472 – If your U.S. corporation or single-member LLC is at least 25% foreign-owned, or if you operate a foreign corporation with U.S. trade or business activities, you likely need to file IRS Form 5472. This information return reports transactions with related foreign or domestic parties under IRC Sections 6038A and 6038C.

Missing the Form 5472 filing deadline or submitting an incomplete form triggers an automatic $25,000 penalty per form—with additional $25,000 penalties every 30 days after IRS notice. This guide, based on the official IRS Form 5472 (Rev. December 2023) and Instructions for Form 5472 (Rev. December 2024, posted February 11, 2025), explains everything for tax years beginning in 2025 (filings in 2026).

Download the official Form 5472 PDF here: https://www.irs.gov/pub/irs-pdf/f5472.pdf
Instructions PDF: Available on IRS.gov/Form5472

What Is IRS Form 5472?

Form 5472 is an information return (not a tax return) that discloses reportable transactions between a “reporting corporation” and related parties. The IRS uses it to monitor transfer pricing, base erosion, and compliance in cross-border related-party dealings.

Purpose (per IRS Instructions): To provide required information under sections 6038A and 6038C when reportable transactions occur during the tax year.

Who Must File Form 5472?

You must file if any of these apply:

  • Your entity is a 25% foreign-owned U.S. corporation (including a foreign-owned domestic disregarded entity or DE, such as a single-member LLC wholly owned by a foreign person).
  • Your entity is a foreign corporation engaged in a U.S. trade or business.

Key definitions (straight from IRS Instructions Rev. Dec 2024):

  • 25% foreign-owned: At least one direct or indirect 25% foreign shareholder owns ≥25% of voting power or value of stock at any time during the tax year.
  • 25% foreign shareholder: A foreign person (individual, corporation, partnership, estate, trust, or foreign government) meeting the 25% threshold. Constructive ownership rules under section 318 apply with modifications (10% instead of 50% in some attribution).
  • Reporting corporation: Includes foreign-owned U.S. DEs treated as corporations solely for section 6038A purposes (effective since 2017).
  • Related party: Includes the 25% foreign shareholder, anyone related under sections 267(b), 707(b)(1), or 482, or to the 25% foreign shareholder.

Foreign-owned U.S. disregarded entities (e.g., single-member LLCs owned 100% by a non-U.S. person) must file Form 5472 + a pro forma Form 1120 even if they have no U.S. income tax filing requirement.

Note: A separate Form 5472 is required for each foreign or U.S. related party with reportable transactions.

What Are Reportable Transactions?

Reportable transactions fall into three categories (reported in Parts IV, V, and VI of the form):

  • Monetary transactions (Part IV – foreign related parties only): Sales, purchases, rents, royalties, interest, dividends, loans, borrowings, reimbursements, guarantees, etc., where money is the sole consideration.
  • Specific transactions for foreign-owned U.S. DEs (Part V): Contributions, distributions, or other transactions connected with formation, dissolution, acquisition, or disposition of the DE.
  • Nonmonetary transactions (Part VI – foreign related parties only): Transfers of property or services without full monetary consideration (report fair market value).

Transactions with U.S. related parties do not go in Parts IV–VI but still require reporting the related party in Part III.

De minimis rule: Amounts ≤ $50,000 (or series of transactions) can be reported as “$50,000 or less.”

All amounts must be in U.S. dollars; attach an exchange-rate schedule for foreign currency.

Exceptions – When You Do NOT Need to File Form 5472?

You are exempt if any of these apply (full list in IRS Instructions):

  1. No reportable transactions in the relevant parts.
  2. A U.S. person files Form 5471 with complete Schedule M (does not apply to foreign-owned DEs).
  3. The related party is a foreign sales corporation filing Form 1120-FSC.
  4. Foreign corporation has no U.S. permanent establishment and files Form 8833.
  5. All gross income is exempt under section 883 with proper reporting.
  6. Both parties are non-U.S. persons and transactions have no U.S.-source or effectively connected income/expense (does not apply to DEs).

Form 5472 Due Dates & Extensions (2026 Filings)

Form 5472 is attached to the reporting corporation’s income tax return and due on the same date (including extensions).

Entity Type Tax Year End Original Due Date Extension (Form 7004)
Calendar-year corporation or foreign-owned DE Dec 31 April 15, 2026 October 15, 2026
Fiscal-year corporation Any 15th day of 4th month after year-end +6 months
Foreign corporation (1120-F) Calendar Generally 15th day of 6th month (June 15 for 2025) Check Form 7004

Special rules for foreign-owned U.S. DEs:

  • File pro forma Form 1120 (only name, address, and Items B & E completed) + Form 5472.
  • Use dedicated filing address/fax: Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201 or fax (300 DPI or higher) to 855-887-7737.
  • Cannot e-file; must mail or fax.
  • Request extension on Form 7004 (enter “Foreign-owned U.S. DE” at top and use Form 1120 code).

How to File IRS Form 5472?

  1. Complete one Form 5472 per related party.
  2. Attach to Form 1120, 1120-F, or pro forma 1120.
  3. Most corporations can e-file with their income tax return.
  4. Foreign-owned DEs: Mail or fax only to the Ogden PIN Unit address above.
  5. Consolidated groups: One consolidated Form 5472 + schedule listing members is allowed.

Enter on Part I:

  • Total number of Forms 5472 filed (line 1g).
  • Total value of all foreign-related-party transactions across all forms (line 1h).

Quick Overview of Form 5472 Parts

  • Part I: Reporting corporation details (EIN, assets, business activity, totals).
  • Part II: Direct and ultimate indirect 25% foreign shareholders (name, address, FTIN, reference ID if needed).
  • Part III: Related party information (U.S. ID or reference ID number – consistent year-to-year).
  • Part IV: Monetary transactions with foreign related parties (detailed lines for sales, interest, loans, etc.).
  • Part V: DE-specific transactions (attach statement).
  • Part VI: Nonmonetary transactions with foreign related parties (FMV).
  • Part VII: Additional info (hybrid mismatches under 267A, FDII section 250 deduction, safe-haven interest rates, section 385 debt, etc.).
  • Part VIII: Cost sharing arrangements (if applicable; attach per CSA).
  • Part IX: Base erosion payments and benefits under section 59A.

Reference ID numbers (for foreign parties without U.S. TIN): Alphanumeric, ≤50 characters, consistent across years. Correlate old/new IDs for changes.

Penalties for Not Filing or Incomplete Form 5472

  • Initial penalty: $25,000 per Form 5472 for failure to file on time, in the correct manner, or substantially complete (including missing records).
  • Continuation penalty: Additional $25,000 for each 30-day period (or fraction) after the 90th day following IRS notice—no maximum.
  • Each member of a consolidated group is separately liable ($25,000+ each).
  • Criminal penalties possible under sections 7203, 7206, 7207.
  • Failure to maintain required records under Reg. §1.6038A-3 also triggers the penalty.

Important: The IRS does not send reminders. Penalties apply even for one-day late filing or minor omissions.

Recordkeeping Requirements

Maintain permanent books and records sufficient to establish the correctness of your tax return and related-party transactions (Reg. §1.6038A-3). Small corporations and de minimis transactions have simplified rules, but filing is still required if reportable transactions exist.

Common Mistakes to Avoid

  • Forgetting to file for each related party.
  • Using the wrong mailing address for foreign-owned DEs.
  • Failing to attach pro forma Form 1120 for DEs.
  • Inconsistent or missing reference ID numbers.
  • Reporting U.S. related-party transactions in Parts IV/VI.
  • Not converting foreign currency properly.

Recent Updates (as of February 2026)

  • Form remains Rev. December 2023; Instructions Rev. December 2024.
  • No major legislative changes to Form 5472 requirements for 2025 tax years.
  • Continued emphasis on foreign-owned DE compliance and base erosion (section 59A) reporting.

Frequently Asked Questions (FAQs)

Q: Do single-member LLCs owned by foreigners need Form 5472?
A: Yes—since 2017, foreign-owned U.S. DEs must file annually with pro forma 1120.

Q: Can I e-file Form 5472?
A: Yes, if attached to an e-filed income tax return (except foreign-owned DEs).

Q: What if I have no transactions?
A: No filing required (but document the absence).

Q: How do I get a reference ID number?
A: You create it (alphanumeric, consistent). Never reuse retired ones.

Final Advice

Filing IRS Form 5472 correctly protects your business from steep penalties and ensures compliance with U.S. international tax rules. Requirements are complex—especially for foreign-owned LLCs, cost-sharing arrangements, or hybrid transactions.

Always consult a qualified U.S. tax professional familiar with international reporting. Rules can change, and your specific facts matter.

For the latest information, visit the official IRS page: IRS.gov/Form5472.

Stay compliant and avoid unnecessary $25,000+ penalties. If you need help determining whether you must file or completing the form, reach out to a tax advisor today.

This guide is for informational purposes only and is not tax or legal advice. All information is sourced directly from IRS.gov publications as of February 2026.