The nine Parts of Form 5472

Short answer

Form 5472 has nine Parts. Parts I to III identify the reporting corporation, its 25% foreign shareholder and the related party; Parts IV to VI describe transactions; Parts VII to IX cover additional information, cost sharing arrangements and base erosion amounts.

What the IRS says

Source: Instructions for Form 5472 (Rev. 12-2024), Form 5472 (Rev. 12-2023).

In plain English

Part I identifies the reporting corporation. For a foreign-owned U.S. DE that is the LLC, not its owner. Part II is about the 25% foreign shareholder: the instructions say that for a foreign-owned U.S. DE, the foreign owner is reported on the lines provided for the 25% foreign shareholder. Part III is about the related party with which the reportable transactions occurred.

Part IV covers monetary transactions with a foreign related party, in rows for amounts received and amounts paid. Part V is the Part for a foreign-owned U.S. DE: it is where the instructions place contributions and distributions, described on an attached statement. Part VI covers nonmonetary and less-than-full-consideration transactions, with an attached schedule.

Part VII asks additional information questions. Part VIII covers cost sharing arrangements. Part IX covers base erosion payments and tax benefits under section 59A. The IRS instructions say which Parts a given kind of filer completes; this page only summarizes what each is for.

Related

• Part IV: monetary transactions
• Part V: foreign-owned U.S. DE transactions
• Part VII lines 42 and 43
• Find a line by its number