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IRS Form 5472 – Foreign-Owned U.S. Entity Reporting

What Is IRS Form 5472?

IRS Form 5472 is an information return used to report certain reportable transactions between a U.S. entity and its foreign owners or related foreign parties. It is required for 25% foreign-owned U.S. corporations and certain foreign corporations engaged in a U.S. trade or business.

Form 5472 is a disclosure form. It does not calculate tax by itself, but it supports IRS oversight of cross-border transactions.


What Is Form 5472 Used For?

Form 5472 is used to:

  • Report transactions between a U.S. entity and foreign related parties
  • Disclose ownership information for 25% foreign-owned entities
  • Support compliance with transfer pricing and related-party rules
  • Provide transparency into cross-border payments, loans, services, and sales

The form helps the IRS monitor transactions that could affect U.S. tax reporting.


Who Is Required to File Form 5472?

Form 5472 is generally required if:

  • A U.S. corporation is 25% or more foreign-owned
  • A foreign corporation is engaged in a U.S. trade or business
  • A U.S. disregarded entity is wholly owned by a foreign person and has reportable transactions

Filing obligations apply even if the entity has little or no income.


When Should You File Form 5472?

Form 5472 is typically filed:

  • With the entity’s income tax return, or
  • Attached to a pro forma return for certain foreign-owned U.S. disregarded entities

Due dates generally align with the entity’s income tax return deadline, including extensions.


IRS Notices This Form Is Commonly Used With

Form 5472 issues often surface alongside IRS notices related to missing information returns or penalties, including:

  • CP15 / penalty notices for failure to file required information returns
  • Audit or examination letters involving related-party transactions
  • Balance-due notices resulting from assessed penalties

Form 5472 itself is a reporting obligation; penalties arise when it is not filed correctly or on time.


When NOT to Use Form 5472

Do not use Form 5472 if:

  • There is no foreign ownership or foreign related-party transaction
  • The entity does not meet the ownership or activity thresholds
  • Another information return applies instead

Filing unnecessarily can create confusion and compliance risk.


What Information Is Required on Form 5472?

Form 5472 generally requires:

  • Identifying information for the reporting entity
  • Ownership details of the foreign owner(s)
  • Description and amounts of reportable transactions
  • Country and relationship information for related parties

Accurate records and documentation are critical.


Where and How to File Form 5472

Form 5472 is filed:

  • Attached to the applicable income tax return, or
  • With a pro forma return when required

Electronic filing is common, but requirements depend on entity type and filing method.


What Happens After You File Form 5472?

After filing:

  • The IRS processes the information return
  • The form may be reviewed during audits or compliance checks
  • Errors or omissions may lead to penalties or follow-up requests

Penalties for failure to file or incomplete filing can be significant.


Related IRS Forms

Other forms commonly associated with foreign ownership or information reporting include:

  • Form 1120 / 1120-F – U.S. corporate income tax returns
  • Form 5471 – Information return of U.S. persons with foreign corporations
  • Form 926 – Return by a U.S. transferor of property to a foreign corporation

Summary

IRS Form 5472 is an information reporting form required for certain foreign-owned U.S. entities and foreign corporations engaged in U.S. business. It discloses related-party transactions and ownership details and carries significant penalties if not filed correctly.


Scope Note

This page explains the purpose and general use of IRS Form 5472. It does not provide legal or tax advice.

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