Do I need to file Form 5472 for my US LLC?

Form 5472 at a glance

What counts as a reportable transaction?

• Sales and purchases of stock in trade (inventory)
• Sales and purchases of tangible property other than stock in trade
• Rents and royalties paid and received
• Sales, purchases, and amounts paid/received for use of intangible property
• Consideration paid and received for technical, managerial, engineering, construction, scientific, or other services
• Commissions paid and received
• Amounts loaned and borrowed (beginning/ending balances or monthly average)
• Interest paid and received
• Premiums paid and received for insurance and reinsurance
• Other amounts paid or received that are taken into account in computing taxable income
• Foreign-owned DE only (Part V): any other transaction under Reg. 1.482-1(i)(7), including amounts paid or received in connection with the formation, dissolution, acquisition, and disposition of the entity, including contributions to and distributions from the entity (e.g., owner capital contributions, owner payment of LLC expenses, distributions to owner)
• Nonmonetary and less-than-full-consideration transactions with the foreign related party (Part VI)

How does the Form 5472 checker work?

The checker applies the rules for foreign-owned US disregarded entities in Treas. Reg. §1.6038A-1 and §1.6038A-2 and the penalty in IRC §6038A(d):

1. Is the owner foreign? If the owner is a US person, the foreign-owned LLC rule does not apply. A multi-member LLC is taxed as a partnership by default and does not file Form 5472.
2. Which years count? Every tax year from the year the LLC was formed (but not before 2017) up to the current year.
3. Was it required that year? A year is "Required" if you said money or value moved between you and the LLC, "Likely" if you weren't sure, and "Not required" if you said nothing moved.
4. Is it at risk? A required year is "at risk" if the original due date has passed, the extended due date has passed and you said it was not filed. A year that is past its original date but still within the extension period shows as "Late unless extended".
5. Potential maximum exposure = (number of at-risk years from 2018 onward × $25,000) + (at-risk years before 2018 × $10,000). The higher "up to" figure also counts the years you weren't sure about. Continuation penalties after an IRS notice are not included.

Due dates follow the IRS rule that a deadline falling on a weekend or legal holiday moves to the next business day (IRC §7503).

What the checker cannot know: whether the IRS has already sent you a notice, whether reasonable-cause relief would be granted, or ownership details such as indirect ownership through other entities. Treat the result as a starting point for a professional review.