Why this exists at all
Form 5472 has never been a standalone filing. Its instructions require it to be attached to the reporting corporation's income tax return. For an ordinary US corporation that is simple: the corporation files a Form 1120 anyway, and the 5472 rides along.
The 2017 change brought a new kind of filer into the regime. A US disregarded entity wholly owned by one foreign person became treated as a domestic corporation separate from its owner for the purposes of these reporting rules — but it still had no income tax return of its own, because for income tax it remains disregarded and its income is the owner's.
So there was an attachment with nothing to attach to. The solution in the instructions is the pro forma Form 1120: use the corporate return as an envelope, complete only enough of it to identify the filer, and let it carry the Form 5472.
"Pro forma" means "as a matter of form"
The phrase is doing real work here. The return is filed as a formality, to satisfy a procedural requirement. It is not a claim that the entity is a taxable corporation, and it does not report the entity's results.
What to complete, and what to leave alone
| Section | What to do | Why |
|---|---|---|
| Top of form | Write FOREIGN-OWNED U.S. DE | Tells the IRS what this filing is, so it is routed correctly. |
| Name | Complete — exact legal name | Must match the EIN record and the Form 5472. |
| Address | Complete | Identifying information. |
| EIN | Complete | Required. The owner's personal number cannot be used. |
| Date incorporated | Complete | From the formation certificate. |
| Total assets | Complete | Book value at year end. Enter 0 if the entity held nothing. |
| Tax year dates | Complete | Normally the calendar year. |
| Income lines | Leave blank | The entity is disregarded for income tax; its income is not reported here. |
| Deduction lines | Leave blank | Same reason. |
| Tax and payments | Leave blank | No tax is computed on a pro forma return. |
| Schedules | Generally not completed | Follow the current instructions; the pro forma filing is deliberately minimal. |
| Signature | Sign and date | An unsigned return can be treated as never filed. |
Swipe the table sideways to see all columns
The two errors that matter most
Filling in the income lines. It feels diligent and it is wrong. A completed Form 1120 reporting income is a different filing from a pro forma cover, and it can create confusion about whether the entity is being treated as a taxable corporation.
Not signing it. The Form 5472 itself has no signature line for this purpose — the signature belongs on the pro forma Form 1120. An unsigned return can be treated as never filed, which puts the statutory penalty back in play even though your package arrived on time.
What the finished package looks like
Two documents, in this order, sent together:
-
Pro forma Form 1120 — on top. Header completed,
FOREIGN-OWNED U.S. DEacross the top, income and tax lines blank, signed and dated. - Form 5472 — behind it. Parts I, II and III completed, transactions in Part V for a disregarded entity, Part VI describing anything non-monetary.
Plus, where relevant, a reasonable-cause statement if the filing is late and the facts support one. More on that →
Four things it does not mean
- It is not an election. Filing a pro forma Form 1120 does not elect corporate taxation. That would require Form 8832 (or Form 2553 for S corporation status), filed deliberately.
- It does not make the LLC a taxpayer. The entity remains disregarded for income tax; its income belongs to the owner and is taxed, or not, according to the owner's position.
- It does not create a US tax liability. No tax is computed on the form. Whether you owe US tax is a separate question determined by your own circumstances.
- It is not a substitute for the owner's own filings. If the owner has US filing obligations of their own, those remain.
Filing it
- When: with the Form 5472, by the return's due date — 15 April for a calendar-year filer, or 15 October with a timely Form 7004. Deadline detail →
- How: generally by mail or fax to the address the current instructions give for foreign-owned DE filings. This package normally cannot be e-filed.
- Verify the address: on IRS.gov, for the year you are filing. It has changed before.
- Keep proof: a tracked mail receipt or a fax confirmation, stored with a copy of everything you sent.
What if my entity is a real corporation, not a disregarded entity?
Then there is no pro forma anything. A US corporation files its actual Form 1120 — complete, with income, deductions and tax computed as normal — and attaches the Form 5472 to it. A foreign corporation with a US trade or business generally files Form 1120-F.
The pro forma mechanism exists solely because a disregarded entity has no return of its own. If you have a return, use it.
Do I file a separate pro forma 1120 for each year I missed?
Yes. Each tax year is a separate filing: one pro forma Form 1120 with one Form 5472 attached, per year, using the form revision applicable to that year where the IRS makes prior-year forms available.
Do not combine several years into one package with a single cover. If you have multiple years outstanding, get professional input on how to present them before sending anything. What to do if you are already late →
Both documents, from one questionnaire
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Questions
What is a pro forma Form 1120?
It is a Form 1120 used purely as a cover sheet for an attached Form 5472. A foreign-owned US disregarded entity has no income tax return of its own, so the IRS instructions direct it to file a Form 1120 on which only the identifying header information is completed, with FOREIGN-OWNED U.S. DE written across the top. No income is reported and no tax is computed.
Do I report my LLC's income on the pro forma 1120?
No. The income, deduction and tax lines are left blank. Completing them would turn the filing into something it is not, because the entity remains disregarded for income tax purposes and its income is the owner's. Only the identifying information at the top of the form is filled in.
Does filing a pro forma 1120 mean my LLC is taxed as a corporation?
No. It does not change your entity classification and it is not an election. The entity remains a disregarded entity for income tax. The pro forma return exists only because the reporting rules treat a foreign-owned disregarded entity as a separate corporation for information-reporting purposes, and the Form 5472 needs a return to attach to.
Can the pro forma Form 1120 be e-filed?
Generally no. A pro forma Form 1120 filed solely to carry a Form 5472 is normally sent by mail or fax to the address the current IRS instructions specify for these filings, rather than through the electronic filing system. Confirm the current address and fax number on IRS.gov before sending, as they have changed in the past.
Who signs the pro forma Form 1120?
The owner or an authorised representative signs and dates it. The signature belongs on the pro forma Form 1120 rather than on the Form 5472. An unsigned return can be treated as never filed, which puts the failure-to-file penalty back in play even though the package arrived on time.
What do I put on the total assets line if the LLC owns nothing?
Enter zero. The line asks for the book value of assets at the end of the tax year, and for many dormant entities that is the bank balance and nothing else. A blank where a figure is expected is a worse outcome than an accurate zero, because omissions are what make a return incomplete.
Scope & limitations
This page is general educational information and is not tax, legal or accounting advice. It describes the ordinary pro forma filing for a foreign-owned US disregarded entity and is not a substitute for the official IRS instructions for the form revision and tax year you are filing. Form layout, required notations and filing addresses change between revisions.
Content reflects the IRS Form 5472 and its instructions as reviewed in 2026. Verify against IRS.gov and consult a qualified US tax professional where your situation is not straightforward.