Plain-English guide

Form 5472 terms in plain English

Short answer

These are the terms the instructions define, in the IRS's own words. Each definition is quoted so it can be checked against the source.

What the IRS says

Source: Instructions for Form 5472 (Rev. 12-2024).

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.
Related party
Related party. A related party is: Any direct or indirect 25% foreign shareholder of the reporting corporation, Any person who is related (within the meaning of section 267(b) or 707(b)(1)) to the reporting corporation, Any person who is related (within the meaning of section 267(b) or 707(b)(1)) to a 25% foreign shareholder of the reporting corporation, or Any other person who is related to the reporting corporation within the meaning of section 482 and the related regulations.
Disregarded entity (DE)
A DE is an entity that is disregarded as an entity separate from its owner for U.S. income tax purposes under Regulations sections 301.7701-2 and 301.7701-3.
Foreign-owned U.S. DE
A foreign-owned U.S. DE is a domestic DE that is wholly owned by a foreign person.
Reference ID number
The length of a given reference ID number is limited to 50 characters and each number must be alphanumeric and no special characters are permitted.

In plain English

A reporting corporation is the filer. A related party is the person or company on the other side of a transaction. A 25% foreign shareholder is an owner holding at least a quarter by vote or value.

A disregarded entity is one the tax rules ignore as separate from its owner. A foreign-owned U.S. DE is a U.S. one owned entirely by a foreign person, which for the limited purposes of section 6038A the instructions treat as separate and classified as a corporation.

A reference ID number is a number used in place of a U.S. identifying number for a foreign related party in some cases. The reference ID page explains the format rules and links the checker.

Related

IRS sources

Quoted text last compared with the IRS document on 2026-10-03. The IRS can revise its forms and instructions; check the current version before you rely on anything here.

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