Form 5472 reports certain related-party transactions of qualifying foreign-owned U.S. corporations and foreign corporations conducting U.S. business.
It is an information return, not a calculation of income tax. Filing may be required even with losses or no tax due.
Reference: IRS — About Form 5472
1. Who May Need to File?
Subject to reportable transactions and exceptions:
- U.S. corporations with at least 25% foreign ownership by vote or value, directly or indirectly
- Foreign corporations conducting U.S. business
- Certain wholly foreign-owned U.S. disregarded entities
2. What Transactions Are Covered?
Review related-party sales, services, rents, royalties, loans, and interest. Generally, prepare a separate form for each related party with reportable transactions.
Foreign-owned disregarded entities may also report contributions, distributions, and formation or dissolution transactions. No sales does not necessarily mean no reportable transactions.
3. How Is It Filed?
Generally, attach it to the corporation’s income tax return by the applicable deadline, including a valid extension.
Foreign-owned U.S. disregarded entities use special procedures involving a pro forma Form 1120.
4. What If It Is Missing?
Failure to file properly and on time, including substantially incomplete filing, generally carries a $25,000 penalty. Continued failure after IRS notification may trigger additional penalties.
Reference: IRS — Instructions for Form 5472
Records to Gather
Ownership charts, related-party agreements and transactions, balances, funding records, and prior returns help determine requirements.
This answer provides general information. Exceptions and special rules require individual review.
Information reviewed: October 15, 2026
