Form 5472 ownership: direct, indirect and attribution rules
Who goes on lines 4 to 7 of Part II, what the attribution explanation is, and when ownership chains take a case out of a self-prepared filing.
Summary
Our answer: if one non-U.S. individual owns your LLC directly, Part II is one block, lines 4a-4e, and lines 6-7 stay blank. If the LLC is owned through a foreign company, a trust or a family arrangement, the direct owner goes on lines 4-5, the ultimate indirect 25% foreign shareholders on lines 6-7, and the instructions require an attached explanation of the attribution of ownership (Rev. Proc. 91-55, Treas. Reg. 1.6038A-1(e)), applying the constructive ownership rules of section 318 as modified for Form 5472. Our reading: that is the point where a self-prepared packet stops being enough; Form 5472 Desk stops at any indirect owner.
Part II: direct 25% foreign shareholders on lines 4-5, ultimate indirect ones on lines 6-7 with an attached attribution explanation; a foreign DE owner is reported as the direct owner.
| Lines 4a-4e | Largest direct 25% foreign shareholderFor a foreign-owned U.S. DE, the foreign owner. |
|---|---|
| Lines 6a-7e | Ultimate indirect 25% foreign shareholdersAttach an explanation of the attribution of ownership. |
| Attribution rules | Section 318, as modifiedInstructions for Form 5472; Rev. Proc. 91-55; Treas. Reg. 1.6038A-1(e). |
| Foreign DE as owner | Reported as the direct ownerInstructions, lines 4b(3)-7b(3). |
| Form 5472 Desk | Direct individual owner onlyAny holding company, trust or chain is a hard stop. |
Our verdict
Direct individual owner: fill lines 4a-4e and leave 6-7 blank. Anything between the person and the LLC: the filing needs an attribution analysis and an attached explanation, and in our reading that is a professional's job, not a self-prepared packet.
Who this page is for, and who it is not for
For: owners checking whether their structure is simple enough to self-prepare. Not for: groups with several layers, trusts or nominee arrangements looking for the attribution analysis itself.
Who goes where in Part II
The Form 5472 has room for two direct and two ultimate indirect 25% foreign shareholders; more go on an attached sheet.
| Structure | Lines 4-5 (direct) | Lines 6-7 (ultimate indirect) | Attachment |
|---|---|---|---|
| One foreign individual owns the LLC | The individual | Blank | None |
| Foreign company owns the LLC; one individual owns the company | The foreign company | The individual | Explanation of the attribution of ownership |
| Foreign disregarded entity owns the LLC | The foreign DE, reported as the direct owner | Its owner, if it is an ultimate indirect 25% foreign shareholder | Explanation of the attribution of ownership |
Next steps
Common questions
Who is the ultimate indirect owner on Form 5472?
The foreign person who, through one or more entities, owns at least 25% of the reporting corporation, determined with the constructive ownership rules of section 318 as modified in the Form 5472 instructions. They go on lines 6 and 7 of Part II, with an attached explanation of the attribution.
My LLC is owned by my company in Germany. What goes on line 4?
The German company, as the direct owner; if it is itself owned 25% or more by individuals, they may be ultimate indirect owners on lines 6-7. The attribution explanation and the company's identifiers make this a case for a professional.
Does Form 5472 Desk handle an indirect owner?
No. The packet supports one foreign individual owning 100% of the LLC directly. Any foreign company, trust, partnership, nominee or shared ownership stops before checkout.
Does Form 5472 Desk file with the IRS?
No. It prepares a self-review packet and checklist. The user reviews, signs where required, and files through the official IRS mail or fax path.
Does this product provide tax advice?
No. It is self-help software for a narrow packet-preparation lane. Treaty positions, ECI analysis, transfer pricing, reasonable cause, notices, and representation are outside scope.
Run the strict Form 5472 checker
Check whether the facts fit the foreign individual, 100% single-member LLC, disregarded entity, current on-time packet lane before preparing anything.
Open checkerRelated guides
Foreign-owned LLC Form 5472 filing guide
A narrow source-linked guide for foreign-owned single-member LLC owners checking the Form 5472 plus pro forma Form 1120 filing lane.
Form 5472 filing requirements for a foreign-owned LLC
Who must file Form 5472, how foreign-owned U.S. disregarded entity rules fit a single-member LLC, and where the Form 5472 Desk lane stops.
Can Form 5472 be e-filed online for a foreign-owned U.S. DE?
A clear e-file answer for foreign-owned U.S. disregarded entities, with the safer route back to the IRS mail/fax checklist.
Official sources for this guide
Last reviewed: .