Short answer: File every missed year now, oldest first. For each year, send a pro forma Form 1120 (a short return that carries the form) with Form 5472 attached. If you have facts that explain the delay, add a signed reasonable-cause statement. A late filing can still bring an IRS penalty. The statement asks the IRS to remove it, and the IRS decides.
This guide is for the owner of a single-member US LLC who is not a US citizen or resident. Maybe you never filed Form 5472 for one or more years. Maybe you filed a Form 1120 on its own, with no Form 5472 attached. Many owners learn about this form late.
Form 5472 is the IRS report of money and property that moved between you and your LLC. It is not a tax bill. A reasonable-cause statement is a signed letter that gives the facts behind a late filing. By the end you will know which years to file, in what order, and what goes into each one. We cover tax years 2023, 2024 and 2025.
At a glance
Find your case in this table. The second column is what to do.
| Your situation | What to do |
|---|---|
| You never filed a year | File that year: pro forma Form 1120 and Form 5472, plus a signed statement if you have facts to give. |
| You filed Form 1120 with no Form 5472 | That year still has no Form 5472. Tell us what you sent and when. |
| You missed several years | Prepare them all, then file them at the same time. |
| Nothing in Parts IV, V or VI for the year | The IRS instructions say no Form 5472 is needed for that year. Keep your records. |
| The year is before 2023 | We do not prepare it. A US tax professional prepares it by hand. |
| The IRS has already written to you | Reply fast, and read our CP215 notice guide. |
| The year is 2026 | Its filing is due April 15, 2027. |
When each year was due
Most owners abroad have no US tax year, so the LLC uses the calendar year. The IRS instructions set that rule for a foreign-owned LLC. These are its dates.
- April 15, 20242023 filing due. October 15, 2024 with Form 7004.
- April 15, 20252024 filing due. October 15, 2025 with Form 7004.
- April 15, 20262025 filing due. October 15, 2026 with Form 7004.
- April 15, 20272026 filing due. This is the next date to meet.
As of November 2026, all three years we cover are past due, extended or not. Our deadlines guide explains Form 7004, the extension request, for the years ahead.
Which years do you file?
Answer these questions for each year. Start with the oldest.
- Is it a single-member LLC with one owner who is not a US citizen or resident, and no US business activity?YesThis guide fits you. Go to the next question.NoOther setups file other forms. Write to us before you file anything.
- Did money or property move between you and the LLC that year, or did either of you give the other goods, services or the use of property for free or below a fair price? Count money you put in, money you took out, loans, and costs you paid for the LLC.YesWe treat that year as one that needs a Form 5472. Go to the next question.NoThe Form 5472 instructions list no filing for a year with nothing in Parts IV, V or VI. Keep your bank and card records.
- Is the year before 2023?YesWe do not prepare earlier years. A US tax professional prepares them by hand. Have one file them in the same round, so no year stays open.NoWe prepare 2023, 2024 and 2025. Tax year 2026 is due April 15, 2027, so it is not late. Go to the next question.
- Did you already send a complete Form 5472 with a Form 1120 for that year?YesThat year is filed. Keep your copies. Tell us if you are not sure it was complete.NoGo to the next question.
- Did you send a Form 1120 for that year, with no Form 5472 attached?YesThe year still lacks its Form 5472. Tell us what you sent and when, and we confirm how to file it.NoFile the pro forma Form 1120 and Form 5472 as one new set.
Check the second question with care. Part V of the form names amounts paid or received “in connection with the formation” and contributions. We treat a fee you paid yourself as one of these. Our pro forma Form 1120 guide and our related-party guide show what counts.
Steps
- List every year the LLC has existed. Start with the year you formed it and end with 2025. Mark each year as filed, Form 1120 only, or nothing filed.
- Mark the years that need a Form 5472. Use the questions above.
- Pull the records for each year. Gather bank and card statements, receipts for fees you paid yourself, and notes on loans between you and the LLC.
- Write down what happened. Note when you formed the LLC, when and how you learned about Form 5472, and what you did next. Use real dates. The IRS page on penalty relief for reasonable cause asks what happened, when it happened, and what you tried.
- Prepare one set for each year. Each set holds a pro forma Form 1120 and a Form 5472, plus a signed statement if you have facts to give. Take care with the forms. The instructions say a “substantially incomplete” Form 5472 counts as a failure to file.
- File all the years at the same time, oldest first. The IRS manual (IRM 20.1.9.5.5) recommends that reasonable cause not be considered for any year “until all delinquent returns have been filed”. A foreign-owned LLC cannot e-file, so fax or mail each set.
- Keep proof, and answer any letter fast. Save the fax confirmation or the mailing receipt, and a copy of every page. If the IRS writes, reply with the same facts and proof.
- Put 2026 on your calendar. That filing is due April 15, 2027. A Form 7004 filed by that date moves it to October 15, 2027.
What goes into one year’s set
Build one set for each year. Do not mix years in one packet.
- Pro forma Form 1120Write Foreign-owned U.S. DE across the top. The instructions say to complete only the LLC's name and address and items B and E on page 1.
- Form 5472File one for each related party you had a transaction with. For most single-owner LLCs, that is the owner alone.
- Statement for Part VCheck the box in Part V. Describe formation costs, contributions and distributions on an attached statement.
- Reasonable-cause statementIf you have facts for the delay, give them, signed under penalties of perjury. Write one for each year.
- Fax or mailA foreign-owned LLC cannot e-file. Use the dedicated fax number or Ogden mailing address in the Form 5472 instructions.
The lines that matter on Form 5472
A quiet LLC has a short form. These are the parts that most often catch late filers.
Form 5472
- Part I, line 3Foreign-owned U.S. DE
- Check the box. It tells the IRS the LLC is a disregarded entity with a foreign owner.
- Part II25% foreign shareholder
- That is you. Give your details here, with a foreign tax ID number, or None if you have none.
- Part IIIRelated party
- Every filer completes it, even when the related party is the same person as in Part II.
- Part IVMoney paid and received
- Report each category in US dollars and attach the exchange rates. If an exact amount cannot be determined, a reasonable estimate (at least 75% and at most 125% of the actual) is allowed.
- Part VFormation, contributions, distributions
- Check the box and describe them on an attached statement. This part is why a quiet year can still need a filing.
Use real records for Part IV and Part V. An estimate is for amounts you cannot find. Our Form 5472 explained guide covers the rest of the form.
If you filed Form 1120 without Form 5472
The Form 5472 instructions say a foreign-owned LLC files a pro forma Form 1120 “with Form 5472 attached”. A Form 1120 on its own leaves the Form 5472 unfiled for that year.
The instructions give no separate steps for adding the form later. The IRS page on delinquent international information returns says to attach them to an amended income tax return. A foreign-owned LLC has no income tax return filing requirement of its own. The pro forma Form 1120 is the return that carries Form 5472.
So we do not guess. Tell us the year, what you sent and how you sent it. We confirm how to file that year before you pay.
- Nothing filed for the yearFile the whole set: pro forma Form 1120 and Form 5472, plus a signed statement if you have facts to give.
- Form 1120 filed aloneForm 5472 is still missing. Tell us what you filed and when. We confirm the route first.
The signed statement
The statement is optional. You add it when you have facts that explain the delay. The rule is in Treas. Reg. 1.6038A-4(b). The company must make “an affirmative showing of all the facts” behind the delay. It does this in a written statement made under penalties of perjury. That means you sign that every fact is true. So write only what you can show.
For a small company, the same rule tells the IRS to apply reasonable cause “liberally”. Small means gross receipts of 20 million dollars or less in the year. The rule names four points:
- You did not know of the requirement.
- You have limited presence in, and contact with, the US.
- You promptly and fully answer requests to file the form.
- You promptly and fully answer requests for books and records.
Our CP215 notice guide explains each point.
An IRS Chief Counsel memo shows what the IRS may look at. It is CCA 202617012. The memo says it “may not be used or cited as precedent”, so we use it only to see which facts to gather. It says the IRS could consider:
- Whether you or the LLC filed a Form 5472 before, and whether you own other entities that did.
- Where the managers are located, and the number and size of transactions with US customers.
- How fast and how fully you answer the IRS.
The memo also says relief should not rest on “a conclusory submission” with no facts or proof. So give dates, and attach papers such as your formation papers, your EIN letter and bank statements. It adds that relief “does not excuse the taxpayer from the requirement to file Form 5472”. The statement never replaces the filing.
We prepare the statement from the facts you give us, and you sign it. We note the late filing where the form requires it and, where it applies, prepare a penalty-relief request with the filing. No one can promise how the IRS decides.
What happens after you file
The base penalty is set by tax year. Treas. Reg. 1.6038A-4(a) sets $25,000 for each taxable year in which the failure occurs. The IRS penalties page gives the same amount for each failure to file a complete and correct Form 5472 by the due date.
A signed statement is a request. The IRS page on delinquent international information returns says you may attach a reasonable cause statement to each late return. It also says “penalties may be assessed without considering the attached reasonable cause statement”. So a notice can still arrive. If it does, reply with the same facts. Our CP215 notice guide walks through the notice.
There is a good reason to file all the years now. The regulation adds $25,000 for each 30-day period only if the failure goes on for more than 90 days after the IRS mails a notice. It also says the added penalty “will cease to accrue” once the form is filed.
What it costs
Each missed year is its own filing, and we price per filing. These are our prices as of November 2026 for a single-member LLC.
- $399A filing made on time
- $750A filing after the original due date, with no Form 7004 on file
- 3Tax years we prepare: 2023, 2024 and 2025
- $99Form 7004, per company per tax year. Included in Full Compliance.
All three years are past due, so each is priced as a late filing. Three late years are three filings at $750 each. Our price covers preparing the filing. Any IRS penalty is separate, and you pay it to the IRS. See the pricing page for our plans and the federal tax filing page for each filing.
Questions
Can I wait until the IRS writes?
Waiting does not remove the form. If the IRS sends a notice and the failure goes on for more than 90 days after it was mailed, the regulation adds $25,000 for each 30-day period. Filing before a notice keeps that from starting.
Is there a special program for late Form 5472?
The IRS page on delinquent international information returns speaks to filers the IRS has not contacted yet. It does not describe a separate program to join. It points them to “normal filing procedures”, with a reasonable cause statement attached to each late return. This guide follows that idea: file each year in the normal way.
Can I file the years myself?
Yes. The forms and instructions are on IRS.gov. A foreign-owned LLC must fax or mail them. Give each year its own complete set, and its own signed statement if you have facts to give.
Next step
Tell us the tax years you missed and what you filed, if anything. We confirm the route for each year before you pay. Start on our federal tax filing page, or write to us if your case is unusual.
Sources checked November 2026
- IRS: Instructions for Form 5472 (revised December 2024)
- eCFR: Treas. Reg. 1.6038A-4, Monetary penalty
- IRS: International information reporting penalties
- IRS: Delinquent international information return submission procedures
- IRS: Penalty relief for reasonable cause
- IRS: Internal Revenue Manual 20.1.9, 5472 penalties and reasonable cause
- IRS Chief Counsel Advice 202617012 (non-precedential, released April 2026)
Our prices and scope come from our own federal tax filing page, read in November 2026.
