09/29/2026
If you are a foreigner owning a U.S. corporation or a U.S. disregarded entity, Form 5472 will apply to you. A new memo from the IRS Office of Chief Counsel changes how penalty abatement requests are reviewed. You will learn what the memo says and why some common excuses no longer work.
What Is Form 5472 and Who Must File It?
Form 5472 is an information return. It reports transactions between a reporting corporation and a foreign or domestic related party.
You must file it if your U.S. corporation is 25 percent or more foreign-owned. You must also file it if you own a foreign-owned U.S. disregarded entity. A disregarded entity is a business, often a single-member LLC, that is not treated as separate from its owner for tax purposes.
For a full breakdown of related forms, see our guide to U.S. tax forms for foreign-owned businesses.
What Happens If You Miss the Deadline?
If you are a foreigner owning a U.S. corporation or a U.S. disregarded entity, Form 5472 will apply to you. A new memo from the IRS Office of Chief Counsel chan