Form 5472 Foreign-Owned US Corp Calculator 2026
Calculate Form 5472 filing requirements for US corporations 25%+ owned by foreign persons. Track reportable transactions by type, penalty exposure timeline, and multi-transaction ledger.
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One form per related-party relationship
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Form 5472 Filing
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Total Reportable Transactions
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Base Penalty ($25K/form)
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Total Penalty Exposure
Form 5472 Compliance Summary
Form 5472 Filing Requirements
Form 5472 must be filed when a 25%-foreign-owned US corporation or a foreign-owned disregarded entity has reportable transactions with a related party. There is no minimum transaction amount β any amount triggers the filing requirement.
Penalty Structure (IRC 6038A)
Base penalty: $25,000 per form per tax year (increased from $10,000 in 2017)
Continuation: $25,000 per 30-day period after 90-day IRS notice (no stated maximum)
Foreign tax credit reduction possible for the applicable tax year
Continuation: $25,000 per 30-day period after 90-day IRS notice (no stated maximum)
Foreign tax credit reduction possible for the applicable tax year
Sources and References (click to expand)
- IRS Form 5472 Instructions β Information Return of a 25% Foreign-Owned US Corporation
- IRC Section 6038A β Information with Respect to Certain Foreign-Owned Corporations
- IRC Section 6038C β Information with Respect to Foreign Corporations Engaged in US Business
- Treasury Reg 1.6038A-2 β Requirement of Return, Form 5472
- IRS Notice 2018-23 β Foreign-Owned Domestic Disregarded Entities and Form 5472
- IRS International β Transfer Pricing and IRC 482 Overview
Extended
Multi-Transaction Ledger and Penalty Timeline
Add reportable transactions by type, SVG bar chart of transaction breakdown, penalty escalation timeline, and aggregate Form 5472 exposure.
Add individual reportable transactions to build a complete Form 5472 ledger.
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No transactions added. Add individual transactions above.
Transaction amounts by type from the main calculator inputs.
Penalty escalation for missed or late Form 5472 filing.
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Frequently Asked Questions
Who must file Form 5472?
Form 5472 must be filed by any US corporation that had a foreign shareholder owning 25% or more of its stock (by vote or value) at any time during the tax year and had one or more reportable transactions with a foreign or domestic related party. Additionally, since 2017, foreign-owned single-member LLCs that are disregarded as entities separate from their foreign owner must also file Form 5472. The form is filed with the corporation's income tax return (or, for disregarded entities, a pro-forma Form 1120) by the due date including extensions.
What are reportable transactions for Form 5472?
Reportable transactions include any exchange of money or property between the 25%-foreign-owned US corporation and a related party: sales or purchases of stock in trade, sales or purchases of tangible or intangible property, rent or license fees, loans and advances, performance of services, commissions, contributions to capital, and any other transfers of property or money. There is no de minimis threshold β even a single dollar of transactions triggers reporting. Related parties include 25%-owners, other corporations in the same ownership chain, and any entity that controls or is controlled by the corporation.
What is the penalty for missing or incomplete Form 5472?
The base penalty under IRC 6038A is $25,000 per Form 5472 per tax year. This was increased from $10,000 by the Tax Cuts and Jobs Act of 2017. If the failure continues for 90 days after IRS notice, an additional $25,000 penalty applies for each 30-day period (or fraction thereof) with no stated maximum. Criminal penalties may also apply for willful failures. The penalty applies to each form separately, so a corporation with multiple related-party relationships requiring separate forms faces multiplied exposure.
Do foreign-owned disregarded entities need to file Form 5472?
Yes. Since the 2017 regulations (Treasury Reg 1.6038A-1), a foreign-owned domestic disregarded entity (FODE) β such as a single-member US LLC owned by a foreign person β must file Form 5472. It must also prepare a pro-forma Form 1120 (with no tax due) solely for the purpose of attaching Form 5472. The FODE must obtain an Employer Identification Number (EIN) and report all monetary transactions, including formation contributions, between the FODE and its foreign owner.
How does Form 5472 interact with transfer pricing rules?
Form 5472 is primarily an information return and does not itself determine the correct pricing of transactions. However, the transactions reported on Form 5472 are subject to the arm's-length standard under IRC 482. If the IRS determines that transactions between the US corporation and its foreign related parties were not at arm's length, it can reallocate income or deductions to reflect the correct tax liability. Large transfer pricing adjustments can result in penalties under IRC 6662(e) equal to 20% of the underpayment, increasing to 40% for gross valuation misstatements.