A Form 5472 + pro forma Form 1120 package looks surprisingly empty the first time you see one. Pro forma Form 1120 is a multi-page corporate tax return with most lines blank; Form 5472 has Parts I through VIII but for a single-member foreign-owned LLC only about three of them actually get data; and the real substance sometimes lives on a standalone Part V Attachment Statement that is not part of either form. This guide walks through exactly what gets filled out, what stays blank, and why.

TL;DR

  • Pro forma Form 1120: Only the header and Item E checkboxes on page 1 get filled. All income and deduction lines stay blank or zero. A handwritten or typed label "Foreign-owned U.S. DE" goes across the top of page 1 per IRS instructions.
  • Form 5472: Parts I, II, III, and IV get filled in. Parts V, VI, VII, VIII depend on what transactions exist. For most foreign-owned single-member LLCs, Part I + II + III + IV are standard and Part V shows up only when there are capital contributions or distributions.
  • Part V Attachment: A separate page (not a field on Form 5472 itself) listing reportable non-monetary or less-than-full-consideration transactions. Required when Form 5472 Part V has an entry.
  • The governing regulation is Treas. Reg. §1.6038A-1(c)(1), which requires the pro forma 1120 specifically so Form 5472 has something to attach to.

Why Two Forms?

Form 5472 is an information return. It cannot be filed on its own — it must be attached to an income tax return. For a foreign-owned single-member LLC treated as a disregarded entity (DE), there IS no real income tax return because the entity is disregarded for federal tax purposes.

Treasury Regulation §1.6038A-1(c)(1) solves this by requiring the DE to file a "pro forma" Form 1120. "Pro forma" here means a placeholder corporate return that exists only to give Form 5472 something to attach to. It does not report income or compute tax. Most of the form stays blank by design.

Pro Forma Form 1120: What Gets Filled In

The top-margin label

The Form 5472 instructions explicitly require writing "Foreign-owned U.S. DE" across the top of page 1 of the pro forma Form 1120. This is the IRS's signal to the PIN Unit in Ogden that this is a pro forma filing and not a real income tax return. Without this label, the return might get routed to regular Form 1120 processing and bounce back.

Header block (top of page 1)

The header block takes the LLC's basic identification data:

  • Name: the LLC's legal name as registered with its state.
  • Address: the LLC's US mailing address (most formation services provide one; it can be your personal US address if you have one).
  • City, State, ZIP: same address.
  • EIN (Box B): the 9-digit number issued by the IRS when the LLC applied for one. Format XX-XXXXXXX.
  • Date incorporated (Box C): the state formation date.
  • Total assets (Box D): the LLC's total assets at year-end. For most foreign-owned DEs this is the bank account balance.

Item E checkboxes

Item E is a row of checkboxes near the header. The four options are:

  1. Initial return
  2. Final return
  3. Name change
  4. Address change

For the LLC's first year of filing, check "Initial return." For subsequent years, leave Item E blank unless the name or address changed, or this is the LLC's final return. Note that "Amended return" is NOT a fifth option on the modern Form 1120 (the IRS removed it some years ago). For amendments, established practice is to write "AMENDED" across the top of page 1 instead.

The income section (Lines 1 through 11)

Blank or zero. A pro forma 1120 for a disregarded entity does not report income to the IRS because the entity is disregarded — income flows to the owner on their own tax return in their country of residence, not on the DE's pro forma return.

The deduction section (Lines 12 through 29a)

Blank or zero. Same reason. The DE reports no deductions.

Tax computation (Lines 30 through 37)

Blank or zero. No tax computation because no income and no deductions.

Signature block (bottom of page 1)

This gets filled in. The authorized person (usually the foreign owner) signs and dates. Title is typically "Member" or "Sole Member." For foreign signers physically outside the US, electronic signature and fax submission are both accepted by the IRS PIN Unit.

Pages 2 through 6

Pro forma 1120 technically has 6 pages (schedules C, J, K, L, M-1, M-2). For a foreign-owned DE, these pages stay blank and some IRS guidance says they can be omitted entirely. The safer path is to include them blank, so the filing is clearly a complete Form 1120 with no data on pages 2 through 6.

Form 5472: Part by Part

Form 5472 has eight numbered parts. For a standard foreign-owned single-member LLC, Parts I, II, III, and IV are always filled. Parts V through VIII depend on what transactions occurred.

Part I — Reporting Corporation

Identifies the LLC filing the form. The fields are:

  • 1a: LLC legal name.
  • 1b: US address.
  • 1b EIN: same EIN that went on Form 1120.
  • 1c: Total assets (matches the 1120 Box D value).
  • 1d: Principal business activity (e.g., "Software consulting").
  • 1e: Principal business activity code (6-digit NAICS). Common foreign-owned LLC codes: 541510 (computer services), 541990 (professional services), 423910 (sporting goods wholesaling), etc.
  • 1f: Total gross payments made to foreign related parties (sum of Part IV payments).
  • 1g: Total gross amounts received from foreign related parties (sum of Part IV receipts).
  • 1h: The larger of 1f or 1g.
  • 1i, 1j: Optional (consolidated filing and initial year checkboxes; 1j is the "first Form 5472 for this corporation" indicator).
  • 1k, 1l, 1m, 1o: Country and countries of principal business (typically US).

Part II — 25% Foreign Shareholder

Information about the foreign owner (the person who owns 25% or more). For a single-member foreign-owned LLC, the owner holds 100% and is always the subject of Part II.

  • 4a: Full legal name.
  • 4a address: Residential address in the owner's country.
  • 4b(1): US taxpayer ID (often blank — most foreign owners have no ITIN/SSN).
  • 4b(2): Reference ID. This is a string the LLC creates to identify the foreign owner. Any reasonable format works; some preparers use initials + a number like "JDOE001."
  • 4b(3): Foreign tax ID if the owner has one (e.g., CPF in Brazil, CUIT in Argentina, RFC in Mexico, NIE in Spain). If no equivalent exists, "N/A" is acceptable.
  • 4c: Country of citizenship.
  • 4d: Country of residence.
  • 4e: Percentage of stock owned directly. For a single-member LLC, this is 100%.

Part III — Related Party

Information about the specific related party the transactions on Part IV happened with. For a single-member foreign-owned LLC, the related party is the same person as the 25% shareholder, so Part III repeats the owner's information.

This feels redundant. It is. The IRS form design assumes a corporation could have multiple foreign related parties, so Part II identifies the 25% shareholder and Part III identifies a specific related party the transactions involve. For a single-member LLC they are one and the same, so the data is duplicated.

Part IV — Monetary Transactions Between Reporting Corporation and Foreign Related Party

A table of categories with dollar amounts. The rows are numbered 8 through 22 with subcategories:

  • Lines 8 through 14: amounts received by the LLC from the foreign related party.
  • Lines 23 through 36 (on page 2): amounts paid by the LLC to the foreign related party.

For each row the LLC enters the total dollar amount for the year. Examples:

  • Line 8 (Sales) — not typical for a holding/consulting DE.
  • Line 13a (Rents) — common if the foreign owner rents space to or from the LLC.
  • Line 14 (Services) — common for consulting LLCs paying the owner for services rendered.
  • Line 16 (Loans) — common when the owner capitalizes the LLC via a loan.
  • Line 20 (Amounts loaned/advanced) — tracks intercompany balances.

For most first-year foreign-owned DEs with minimal activity, Part IV has only a couple of non-zero rows (typically Line 14 for services or Line 20 for capital movements).

Part V — Reportable Transactions of a Reporting Corporation That Is a Foreign-Owned U.S. DE

Part V on the form itself is small: it asks whether certain reportable transactions occurred and points to a separate statement for the details. This is the "Part V Attachment" discussed below.

Part V captures capital contributions (money the owner put into the LLC) and distributions (money the LLC paid out to the owner) that are NOT already reported under Part IV. For a typical first-year LLC where the owner wired money in to capitalize the entity, Part V applies.

Part VI — Non-Monetary and Less-Than-Full-Consideration Transactions

Uncommon. Applies when the LLC or the owner transferred property (not money) or received less than fair value. For most cash-business foreign-owned DEs, Part VI stays blank.

Part VII — Additional Information

A few yes/no questions about the reporting corporation's business. Answer based on actual facts. Most first-year DEs answer "No" to all.

Part VIII — Cost Sharing Arrangement

Extremely uncommon for single-member foreign-owned LLCs. Applies only if the LLC is a participant in a formal cost-sharing arrangement, which is typically a large-corporate structure. For almost all individual-owned LLCs, Part VIII stays blank.

The Part V Attachment Statement

When Part V of Form 5472 indicates reportable capital contributions or distributions, the IRS requires a separate attachment listing each one. This attachment is not part of Form 5472 itself — it is a standalone page usually titled "Form 5472 Part V Attachment Statement" or "Reportable Transactions of a Foreign-Owned U.S. Disregarded Entity."

The attachment typically includes:

  • LLC name and EIN at the top.
  • A table of transactions: date, type (capital contribution / distribution), description, and amount in USD.
  • A total at the bottom matching the figure referenced in Part V.

For example, an LLC whose owner wired $10,000 in January to capitalize the entity and then took a $4,000 distribution in November would list both rows and total to $14,000.

The attachment gets physically stapled or inserted into the fax package between Form 5472 page 2 and the remaining pages. Order: 5472 page 1 → 5472 page 2 → Part V attachment → 5472 page 3 (instructions).

How the Pieces Fit Together in a Fax Package

A complete fax to the IRS PIN Unit in Ogden (fax number 855-887-7737) has pages in this order:

  1. Cover letter (if amendment or late filing with reasonable cause).
  2. Pro forma Form 1120 page 1 (filled).
  3. Pro forma Form 1120 pages 2 through 6 (blank or omitted).
  4. Form 5472 page 1 (Parts I, II, III, part of IV).
  5. Form 5472 page 2 (rest of Part IV, Part V indicator).
  6. Part V Attachment Statement (if applicable).
  7. Form 5472 page 3 (Parts VI, VII, VIII — mostly blank for most DEs).

Total page count for a typical first-year filing: 9 to 11 pages. Larger if there are many Part V transactions (the attachment can span multiple pages).

Common Fill-Out Mistakes

Filling out the income section of pro forma 1120

Don't. The pro forma 1120 reports no income by design. Entering income figures turns the filing into a real Form 1120 and can create a tax obligation the DE does not actually have.

Using mismatched EINs between the two forms

The EIN on Form 1120 Box B and Form 5472 Box 1b must match. A mismatch gets the package bounced back.

Omitting the "Foreign-owned U.S. DE" top-margin label

Without this label, the filing can be processed as a normal Form 1120 and generate tax correspondence. The label is small but essential.

Entering the owner's US address on Part II

Part II wants the owner's address in their country of residence, not a US address. If the owner has a US correspondence address, it goes on Form 1120 for the LLC; Part II of 5472 is the owner's home-country address.

Skipping the Part V attachment

If Part V has a non-zero entry, the attachment is required. Form 5472 alone does not have room for the transaction detail.

How Filabl Fills It Out

Filabl's PDF filler programmatically populates both forms based on your bank statement data and LLC profile. For Form 1120 it fills the header block, Item E checkboxes, and signature, and leaves the rest blank per the pro forma rules. For Form 5472 it fills Parts I through IV from the LLC profile and transaction classifications, generates a Part V attachment automatically from classified capital contributions and distributions, and stamps "AMENDED" on page 1 when the filing is a correction to a prior submission.

The whole package comes out formatted for direct IRS fax submission: pages in the right order, correct top-margin labels, and consistent EINs across the two forms.

This article describes form-filling mechanics for the most common foreign-owned single-member LLC case. Corporations with multiple foreign related parties, complex transactions, or non-standard ownership structures may have additional parts of Form 5472 that apply. For complex cases consult a qualified tax professional.