Plain-English guide
Who files Form 5472? What the IRS instructions say
Short answer
The instructions say that, generally, a reporting corporation files Form 5472 if it had a reportable transaction with a related party, and they list exceptions. Whether that describes any particular entity depends on facts this page does not know.
What the IRS says
Source: Instructions for Form 5472 (Rev. 12-2024).
Generally, a reporting corporation must file Form 5472 if it had a reportable transaction with a foreign or domestic related party.
It had no reportable transactions of the types listed in Parts IV and VI of the form and, in the case of a reporting corporation that is a foreign-owned U.S. DE, also had no reportable transactions of the type listed in Part V of the form.
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.
This exception does not apply to foreign-owned U.S. DEs.
In plain English
Everything turns on three defined terms: reporting corporation, related party and reportable transaction. The glossary page quotes each definition. Revenue is not one of the terms: the instructions describe the requirement in terms of reportable transactions.
The exceptions in the instructions are specific. Several of them say they do not apply to a foreign-owned U.S. DE. Reading them correctly depends on facts about an entity and its owner, which is why a general page like this one cannot apply them to anyone.
If you want an answer about a particular entity, that is a question for a qualified tax professional. The IRS instructions and Regulations sections 1.6038A-1 and 1.6038A-2 are the primary sources.
A hypothetical, only to show the structure of the rule
The rule has the shape: an entity is a reporting corporation, and it had at least one reportable transaction with a related party during its tax year. If either part is missing, the general rule as written is not met. Which parts are met for a given entity is exactly what this page cannot decide.
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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