Purpose and Overview
Form 5472 is an IRS information return for reporting reportable transactions between a U.S. corporation or a foreign corporation engaged in a U.S. trade or business and related foreign parties. Its goal is to provide transparency on income, deductions, and transfers that could shift taxable income out of the United States.
Who Must File
A U.S. corporation that is 25 percent foreign–owned or a foreign corporation with a U.S. permanent establishment must file Form 5472 when it has reportable transactions with a related party. Reportable transactions include sales, rents, royalties, interest, and service fees.
Filing Requirements
Form 5472 must be attached to the filer’s timely filed Form 1120 or 1120-F, including extensions. Each related–party transaction must be detailed by type, amount, and accounting method.
Penalties
Failure to file or to report complete information may result in a penalty of $25,000 per missing or incomplete form. Continued failure after IRS notification can trigger additional penalties every 30 days, up to a maximum.
