My LLC has two foreign owners — do I file one Form 5472 or two?

For a US C-Corporation with two 25%+ foreign shareholders, you file one Form 5472 per foreign shareholder with whom the corporation had reportable transactions. If both shareholders had transactions, you file two Forms 5472. For a single-member LLC (disregarded entity), by definition there is only one owner — so the multi-owner question applies differently (see the section on disregarded entities).

What if one owner owns 30% and the other owns 20%?

For a US C-Corporation, the 25% threshold is assessed separately for each shareholder. The 30% owner exceeds the threshold and triggers Form 5472 filing if they had reportable transactions. The 20% owner does not meet the 25% threshold alone — but may still be considered under the attribution rules if they are related to the 30% owner. Attribution rules under IRC § 318 can combine ownership interests of related parties.

We have three equal foreign owners (33% each). How many forms?

For a US C-Corporation with three foreign owners at 33% each, each owner independently meets the 25% threshold. If each had reportable transactions with the corporation, you file three separate Forms 5472 — one for each 25% foreign shareholder.

Can the penalty reach $75,000 for one LLC with three owners?

Yes. If a US LLC (taxed as a corporation) has three foreign owners who each had reportable transactions, and the LLC fails to file all three required Forms 5472 for one year, the total penalty exposure is $75,000 ($25,000 × 3 forms). This compounds across years — three years of non-filing for three owners = $225,000 in potential penalties.

Do all owners need ITINs?

Each foreign owner identified on Form 5472 must have a US taxpayer identification number — either a Social Security Number (SSN), Individual Taxpayer Identification Number (ITIN), or, for foreign entities, an Employer Identification Number (EIN). If any foreign owner lacks a US TIN, they should apply for an ITIN using Form W-7 before filing.

Form 5472 With Multiple Foreign Owners

Two or more foreign owners on a US LLC? Learn how many Form 5472 returns are required, how the 25% threshold works with multiple owners, and how to report each owner's transactions.