This Form 5472 guide explains the IRS Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. Form 5472 reports the transactions specified for a reporting corporation under its applicable rules. Foreign ownership and transactions with related parties must be examined together. An entity with little or no taxable profit can still need a reporting analysis, including the special rules for covered foreign-owned U.S. disregarded entities.
Reviewed October 31, 2026. This is an independent guide. The version and availability information below identifies the IRS documents used for this page.
What Form 5472 does and who prepares it
A reporting corporation files the information return when the covered ownership and reportable-transaction rules apply.
For the connected reporting route, see Form 1120. Keep the role of that document separate from the task explained on this page.
| Official form | Form 5472 |
|---|---|
| IRS title | Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business |
| Guide period | the applicable reporting period |
| Target version | Dec 2023 |
| Availability | Current IRS catalog PDF |
| Last checked | October 31, 2026 |
Get the Form 5472 PDF and check its status
Use the IRS source to confirm the document before completing a real filing. The download link is a reference to the official file; it is not a statement that every copy inside the PDF may be printed and submitted. Follow any instructions about electronic filing, scannable copies, recipient copies or attachments.
Which version of Form 5472 should you use?
This form follows a revision or continuing-use format rather than a new title for every calendar year. Check the revision printed on the document and the period requested inside it. A revision date, transaction date and tax year are different pieces of information. The current document should be read with the instructions that apply to the actual transaction or return.
Records to gather for Form 5472
- Entity ownership and classification records.
- Related-party transaction ledger.
- Capital contribution and distribution records.
- Income tax return information.
- Related-party identifying details.
Keep a working reconciliation with these records. It should show the source of each reported item, any correction made before filing and the reason a different amount appears on a connected form. This is especially useful when a statement is corrected or a prior-year balance continues into the current calculation.
How to work through Form 5472
- Confirm applicability. Start with the purpose, filer category and version of the form. Complete any eligibility or applicability question before spending time on the numerical calculation.
- Prepare the source workpapers. Gather the records listed below and reconcile their totals. Keep prior-year balances, current-year transactions and estimated payments separate where they serve different purposes.
- Complete dependent calculations first. When a line refers to another form, schedule or worksheet, finish that supporting calculation first. Preserve any classification, limitation and carryforward information.
- Follow the line sequence. Use the actual line labels and arithmetic in the applicable form. A line number from an older version may refer to something different after a revision.
- Reconcile the filing package. Check names, identifying numbers, tax periods, totals and required attachments. Then use the filing method, signature process and deadline that apply to this filer and form.
Form-specific IRS instructions and reporting details
The following points retain the operative wording of the IRS documents linked above. Read each point with its stated conditions and the applicable form version. References to another form or section describe a connected requirement; they do not mean that every reader must file every referenced document.
(Use with December 2023 revision of Form 5472) Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business Section references are to the Internal Revenue Code unless otherwise noted.
Use Form 5472 to provide information required under sections 6038A and 6038C when reportable transactions occur during the tax year of a reporting corporation with a foreign or domestic related party.
Additional reporting conditions
Definitions Reporting corporation. A reporting corporation is either: • A 25% foreign-owned U.S. corporation (including a foreign-owned U.S. disregarded entity (DE)), or • A foreign corporation engaged in a trade or business within the United States. 25% foreign owned. A corporation is 25% foreign owned if it has at least one direct or indirect 25% foreign shareholder at any time during the tax year. 25% foreign shareholder.
Generally, a foreign person (defined later) is a 25% foreign shareholder if the person owns, directly or indirectly, at least 25% of either: • The total voting power of all classes of stock entitled to vote, or • The total value of all classes of stock of the corporation. The constructive ownership rules of section 318 apply with the following modifications to determine if a corporation is 25% foreign owned. Substitute “10%” for “50%” in section 318(a)(2)(C).
Do not apply sections 318(a)(3)(A), (B), and (C), so as to consider a U.S. person as owning stock that is owned by a foreign person. Direct 25% foreign shareholder. A foreign person is a direct 25% foreign shareholder if it owns directly at least 25% of the stock of the reporting corporation by vote or value.
Calculations and supporting information
Note. Exception 6 does not apply to foreign-owned U.S. DEs. Consolidated returns. If a reporting corporation is a member of an affiliated group filing a consolidated income tax return, Regulations section 1.6038A-2 may be satisfied by filing a U.S. consolidated Form 5472. The common parent must attach to Form 5472 a schedule stating which members of the U.S. affiliated group are reporting corporations under section 6038A, and which of those members are joining in the consolidated filing of Form 5472.
The schedule must show the name, address, and employer identification number (EIN) of each member who is including transactions on the consolidated Form 5472. Note. A member is not required to join in filing a consolidated Form 5472 just because the other members of the group choose to file one or more Forms 5472 on a consolidated basis.
File Form 5472 as an attachment to the reporting corporation's income tax return by the due date (including extensions) of that return.
If you file your income tax return electronically, see the information about electronic filing. If you are a foreign-owned U.S. DE, you cannot file Form 5472 electronically. See Foreign-owned U.S. DEs under When and Where To File, earlier, for acceptable methods of filing.
A reporting corporation that uses an accrual method of accounting must use accrued payments and accrued receipts for purposes of computing the total amount to enter on each line of Form 5472. See Regulations section 1.6038A-2(b)(10).
Exceptions and related reporting
A reporting corporation must keep the permanent books of account or records as required by section 6001. These books must be sufficient to establish the correctness of the reporting corporation’s federal income tax return, including information or records that might be relevant to determine the correct treatment of transactions with related parties. See Regulations section 1.6038A-3 for more detailed information. Also, see Regulations sections 1.6038A-1(h) and 1.6038A-1(i) for special rules that apply to small corporations and reporting corporations with related party transactions of de minimis value.
Note. Only 25% foreign-owned U.S. corporations, including foreign-owned U.S. DEs, complete Part II. For a foreign-owned U.S. DE, report the information for the foreign owner on the lines provided for the 25% foreign shareholder. The form provides sufficient space to report information for two direct 25% foreign shareholders and two ultimate indirect 25% foreign shareholders. If more space is needed, show the information requested in Part II on an attached sheet.
Report on lines 4a through 4e information about the direct 25% foreign shareholder who owns (by vote or value) the largest percentage of the stock of the U.S. reporting corporation. Report on lines 5a through 5e information about the direct 25% foreign shareholder who owns (by vote or value) the second largest percentage of the stock of the U.S. reporting corporation.
Further form details
Line 8b(1). Enter the related party's U.S. identifying number, if any. For individuals, enter an SSN, or an ITIN issued by the IRS. For all other entities, enter an EIN. Line 8b(2). If the related party is a foreign person, enter the related party's reference ID number, if required. A reference ID number is required only in cases where no U.S. identifying number was entered for the foreign related party on line 8b(1). However, filers are permitted to enter both an EIN and a reference ID number.
If applicable, enter the reference ID number you have assigned to the foreign related party. See Reference ID number, earlier, for more information.
Further form details
Part VI—Nonmonetary and Less-Than-Full Consideration Transactions Between the Reporting Corporation and the Foreign Related Party Note. Do not complete Part VI for transactions with a domestic related party. If the related party is a foreign person, the reporting corporation must attach a schedule describing each reportable transaction or group of reportable transactions. The description must include sufficient information so that the nature and approximate monetary value of the transaction or group of transactions can be determined. The schedule should include: 1.
A description of all property (including monetary consideration), rights, or obligations transferred from the reporting corporation to the foreign related party and from the foreign related party to the reporting corporation; 2. A description of all services performed by the reporting corporation for the foreign related party and by the foreign related party for the reporting corporation; and 3. A reasonable estimate of the FMV of all properties and services exchanged, if possible, or some other reasonable indicator of value. See the instructions for Part IV, earlier, for information on reasonable estimates and small amounts.
Reading the lines and boxes
These selected labels come from the linked target PDF. They are a reading aid, not a replacement for the full line instructions or a completed calculation. Match the label and document version before transferring any amount.
| Line or box | Label in the source form | What to check |
|---|---|---|
| 1a | Name of reporting corporation | Use the identity of the person or entity requested on this line. Check that the name and identification number agree with the underlying tax records. |
| 1d | Principal business activity | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
| 1f | Total value of gross payments made or received | Follow the stated arithmetic and line references in sequence. Complete the referenced inputs first and retain the worksheet supporting the result. |
| 1i | Check here if this is a | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
| 1m | Date of incorporation | Use the date or tax period requested by this particular field. A payment date, acquisition date and return year can describe different facts. |
Further selected fields
| Line or box | Label in the source form | What to check |
|---|---|---|
| 2 | Check here if, at any time during the tax year, any foreign person owned, directly or indirectly, at least 50% of (a) the total voting power of all | Follow the stated arithmetic and line references in sequence. Complete the referenced inputs first and retain the worksheet supporting the result. |
| 3 | Check here if the reporting corporation is a foreign-owned domestic disregarded entity (foreign-owned U.S. DE) treated as a corporation for | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
| 4a | Name and address of direct 25% foreign shareholder | Use the identity of the person or entity requested on this line. Check that the name and identification number agree with the underlying tax records. |
| 4b(1) | U.S. identifying number, if any | Use the identity of the person or entity requested on this line. Check that the name and identification number agree with the underlying tax records. |
| 4c | Principal country(ies) where | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
A practical example
A foreign-owned U.S. entity receives an owner contribution and makes related-party payments. Its preparer checks the reporting-entity and transaction rules before deciding whether a separate information return must accompany the required filing.
This example illustrates the order of the review. It does not assume an unverified deduction, exemption, treaty rate or final tax amount. The applicable form instructions and the actual records determine the result.
Common mistakes to avoid with Form 5472
- Do not assume no tax due means no information return.
- Distinguish reportable transactions from only ordinary sales revenue.
- Review the special filing route for a covered disregarded entity.
Questions about Form 5472
Does receiving or downloading this form mean I must file it?
A reporting corporation files the information return when the covered ownership and reportable-transaction rules apply. The form purpose and the applicable filing or furnishing conditions determine the action. Downloading a blank PDF does not itself create a filing obligation or establish eligibility for a tax benefit.
Is the revision date always the same as the tax year?
No. Some forms show a tax year, while continuing-use forms show a revision date and ask separately for the reporting period. Check the actual document and instructions. Do not relabel a payment or transaction solely because it was reported in a later calendar year.
What should I do if the underlying information is wrong?
Do not assume no tax due means no information return. Keep the original record and the correction trail. The issuer correction process, an amended return and an updated certificate can be different procedures. Choose the process that matches the document and the actual error.
Which records should I keep with the completed form?
Retain the source documents, applicable worksheets, submitted version and filing or furnishing confirmations. For this form, the working file should include entity ownership and classification records, related-party transaction ledger, capital contribution and distribution records. Keep continuing balances and prior-year support for as long as they remain relevant under the applicable recordkeeping rules.
Related forms and next steps
Use these guides when the connected issue applies to your records. Each page has its own purpose, reporting year and availability status.