Form 5472

(Rev. December 2023)

Department of the Treasury 

Internal Revenue Service 

Information Return of a 25% Foreign-Owned U.S. Corporation or a 

Foreign Corporation Engaged in a U.S. Trade or Business 

(Under Sections 6038A and 6038C of the Internal Revenue Code)

Go to www.irs.gov/Form5472 for instructions and the latest information.

For tax year of the reporting corporation beginning , , and ending , 

Note: Enter all information in English and money items in U.S. dollars. 

OMB No. 1545-0123 

Part I Reporting Corporation (see instructions). All reporting corporations must complete Part I. 

1a Name of reporting corporation 

Number, street, and room or suite no. (If a P.O. box, see instructions.)

City or town, state, and ZIP code (If a foreign address, see instructions.)

1b Employer identification number

1c Total assets 

$ 

1d Principal business activity 1e Principal business activity code

1f Total value of gross payments made or received 

reported on this Form 5472. See instructions.

$ 

1g Total number of Forms 5472 

filed for the tax year 

1h Total value of gross payments made or received 

reported on all Forms 5472. See instructions. 

$ 

1i Check here if this is a 

consolidated filing of 

Form 5472 . .

1j Check here if this is the initial year for 

which the U.S. reporting corporation 

is filing a Form 5472 . . . .

1k Total number of Parts VIII 

attached to Form 5472 

1l Country of incorporation 

1m Date of incorporation 1n Country(ies) under whose laws the reporting 

corporation files an income tax return as a resident

1o Principal country(ies) where business is conducted

2 Check here if, at any time during the tax year, any foreign person owned, directly or indirectly, at least 50% of (a) the total voting power of all

classes of the stock of the reporting corporation entitled to vote, or (b) the total value of all classes of stock of the reporting corporation . 

3 Check here if the reporting corporation is a foreign-owned domestic disregarded entity (foreign-owned U.S. DE) treated as a corporation for 

purposes of section 6038A. See instructions . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part II 25% Foreign Shareholder (see instructions)

Check here if any direct (or ultimate indirect) 25% foreign shareholder listed in Part II is a surrogate foreign 

corporation under section 7874(a)(2)(B). 

4a Name and address of direct 25% foreign shareholder 

4b(1) U.S. identifying number, if any 4b(2) Reference ID number (see instructions) 4b(3) Foreign taxpayer identification number (FTIN), if any 

(see instructions)

4c Principal country(ies) where 

business is conducted 

4d Country of citizenship, 

organization, or incorporation 

4e Country(ies) under whose laws the direct 25% foreign

shareholder files an income tax return as a resident 

5a Name and address of direct 25% foreign shareholder 

5b(1) U.S. identifying number, if any 5b(2) Reference ID number (see instructions) 5b(3) FTIN, if any (see instructions)

5c Principal country(ies) where 

business is conducted 

5d Country of citizenship, 

organization, or incorporation 

5e Country(ies) under whose laws the direct 25% foreign

shareholder files an income tax return as a resident 

6a Name and address of ultimate indirect 25% foreign shareholder 

6b(1) U.S. identifying number, if any 6b(2) Reference ID number (see instructions) 6b(3) FTIN, if any (see instructions)

6c Principal country(ies) where 

business is conducted 

6d Country of citizenship, 

organization, or incorporation 

6e Country(ies) under whose laws the ultimate indirect 25% foreign 

shareholder files an income tax return as a resident 

7a Name and address of ultimate indirect 25% foreign shareholder 

7b(1) U.S. identifying number, if any 7b(2) Reference ID number (see instructions) 7b(3) FTIN, if any (see instructions)

7c Principal country(ies) where 

business is conducted 

7d Country of citizenship, 

organization, or incorporation 

7e Country(ies) under whose laws the ultimate indirect 25% foreign 

shareholder files an income tax return as a resident 

For Paperwork Reduction Act Notice, see instructions. Cat. No. 49987Y Form 5472 (Rev. 12-2023) 
Form 5472 (Rev. 12-2023) Page 2 

Part III Related Party (see instructions). All reporting corporations must complete this question and the rest of Part III.

Check applicable box: Is the related party a foreign person or U.S. person?

8a Name and address of related party 

8b(1) U.S. identifying number, if any 8b(2) Reference ID number (see instructions) 8b(3) FTIN, if any (see instructions)

8c Principal business activity 8d Principal business activity code

8e Relationship—Check boxes that apply: Related to reporting corporation Related to 25% foreign shareholder 25% foreign shareholder

8f Principal country(ies) where business is conducted 8g Country(ies) under whose laws the related party files an income tax return as a 

resident 

Part IV Monetary Transactions Between Reporting Corporations and Foreign Related Party (see instructions)

Caution: Part IV must be completed if the “foreign person” box is checked in the heading for Part III. 

If estimates are used, check here.

9 Sales of stock in trade (inventory) . . . . . . . . . . . . . . . . . . . . . . . . 9

10 Sales of tangible property other than stock in trade . . . . . . . . . . . . . . . . . . . 10

11 Platform contribution transaction payments received . . . . . . . . . . . . . . . . . . 11

12 Cost sharing transaction payments received . . . . . . . . . . . . . . . . . . . . . 12

13a Rents received (for other than intangible property rights) . . . . . . . . . . . . . . . . . 13a

b Royalties received (for other than intangible property rights) . . . . . . . . . . . . . . . . 13b

14 Sales, leases, licenses, etc., of intangible property rights (for example, patents, trademarks, secret formulas) . . 14

15 Consideration received for technical, managerial, engineering, construction, scientific, or like services . . . . 15

16 Commissions received . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

17 Amounts borrowed (see instructions) a Beginning balance b Ending balance or monthly average 17b

18 Interest received . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

19 Premiums received for insurance or reinsurance . . . . . . . . . . . . . . . . . . . . 19

20 Loan guarantee fees received . . . . . . . . . . . . . . . . . . . . . . . . . 20

21 Other amounts received (see instructions) . . . . . . . . . . . . . . . . . . . . . . 21

22 Total. Combine amounts on lines 9 through 21 . . . . . . . . . . . . . . . . . . . . 22

23 Purchases of stock in trade (inventory) . . . . . . . . . . . . . . . . . . . . . . . 23

24 Purchases of tangible property other than stock in trade . . . . . . . . . . . . . . . . . 24

25 Platform contribution transaction payments paid . . . . . . . . . . . . . . . . . . . . 25

26 Cost sharing transaction payments paid . . . . . . . . . . . . . . . . . . . . . . 26

27a Rents paid (for other than intangible property rights) . . . . . . . . . . . . . . . . . . . 27a

b Royalties paid (for other than intangible property rights) . . . . . . . . . . . . . . . . . . 27b

28 Purchases, leases, licenses, etc., of intangible property rights (for example, patents, trademarks, secret formulas) 28

29 Consideration paid for technical, managerial, engineering, construction, scientific, or like services . . . . . 29

30 Commissions paid . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

31 Amounts loaned (see instructions) a Beginning balance b Ending balance or monthly average 31b

32 Interest paid . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

33 Premiums paid for insurance or reinsurance . . . . . . . . . . . . . . . . . . . . . 33

34 Loan guarantee fees paid . . . . . . . . . . . . . . . . . . . . . . . . . . 34

35 Other amounts paid (see instructions) . . . . . . . . . . . . . . . . . . . . . . . 35

36 Total. Combine amounts on lines 23 through 35 . . . . . . . . . . . . . . . . . . . . 36

Part V Reportable Transactions of a Reporting Corporation That Is a Foreign-Owned U.S. DE (see instructions)

Describe on an attached separate sheet any other transaction as defined by Regulations section 1.482-1(i)(7), 

such as amounts paid or received in connection with the formation, dissolution, acquisition, and disposition 

of the entity, including contributions to and distributions from the entity, and check here.

Part VI Nonmonetary and Less-Than-Full Consideration Transactions Between the Reporting Corporation 

and the Foreign Related Party (see instructions)

Describe these transactions on an attached separate sheet and check here.

Form 5472 (Rev. 12-2023) 
Form 5472 (Rev. 12-2023) Page 3 

Part VII Additional Information. All reporting corporations must complete Part VII. 

37 Does the reporting corporation import goods from a foreign related party? . . . . . . . . . . . . . . Yes No

38a If “Yes,” is the basis or inventory cost of the goods valued at greater than the customs value of the imported goods? . Yes No

b If “Yes,” attach a statement explaining the reason or reasons for such difference. 

c If the answers to questions 37 and 38a are “Yes,” were the documents used to support this treatment of the imported 

goods in existence and available in the United States at the time of filing Form 5472? . . . . . . . . . . . Yes No

39 During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)? . . . . Yes No

If “Yes,” complete Part VIII as instructed below.

40 a During the tax year, did the reporting corporation pay or accrue any interest or royalty for which the deduction is not 

allowed under section 267A? See instructions . . . . . . . . . . . . . . . . . . . . . . . Yes No

b If “Yes,” enter the total amount of the disallowed deductions . . . . . . . . . . . . . . . . . $

41 a Is the reporting corporation claiming a foreign-derived intangible income (FDII) deduction (under section 250) with respect 

to any transactions with the foreign related party? If “Yes,” complete lines 41b, 41c, and 41d. See instructions . . . Yes No

b Enter the amount of gross receipts derived from all sales of general property to the foreign related party that the reporting 

corporation included in its computation of foreign-derived deduction eligible income (FDDEI). See instructions . . . $

c Enter the amount of gross receipts derived from all sales of intangible property to the foreign related party that the 

reporting corporation included in its computation of FDDEI. See instructions . . . . . . . . . . . . . $

d Enter the amount of gross receipts derived from all services provided to the foreign related party that the reporting 

corporation included in its computation of FDDEI. See instructions . . . . . . . . . . . . . . . $

42 Did the reporting corporation have any loan to or from the related party to which the safe-haven rate rules of Regulations 

section 1.482-2(a)(2)(iii)(B) are applicable, and for which the reporting corporation used a rate of interest within the relevant 

safe-haven range (100% to 130% of the applicable Federal rate (AFR) for the relevant term)? . . . . . . . . . Yes No

b Did the reporting corporation have any loan to or from the related party to which the safe-haven rate rules of Regulations 

section 1.482-2(a)(2)(iii)(B) are applicable, and for which the reporting corporation used a rate of interest outside the 

relevant safe-haven range (100% to 130% of the AFR for the relevant term)? . . . . . . . . . . . . . . Yes No

43 a Did the reporting corporation issue a covered debt instrument in any of the transactions described in Regulations section 

1.385-3(b)(2) during the tax year with respect to a related party that is a corporation, or, did the reporting corporation issue 

or refinance indebtedness owed to a related party that is a corporation during the 36 months before or after the date of a 

distribution or acquisition described in Regulations section 1.385-3(b)(3)(i) made by the reporting corporation, and either 

the issuance or refinance of indebtedness, or the distribution or acquisition, occurred during the tax year? . . . . . Yes No

b If the answer to question 43a is “Yes,” provide the following.

(1) The amount of such transaction(s), distribution(s), and acquisition(s) . . . . . . . . . . . . . . $

(2) The amount of such related party indebtedness . . . . . . . . . . . . . . . . . . . . $

Part VIII Cost Sharing Arrangement (CSA)

Note: Complete a separate Part VIII for each CSA in which the reporting corporation was a participant during the tax year. Report all amounts in U.S. 

dollars. (See instructions.)

44 Provide a brief description of the CSA with respect to which this Part VIII is being completed.

45 During the course of the tax year, did the reporting corporation become a participant in the CSA? . . . . . . . Yes No

46 Was the CSA in effect before January 5, 2009? . . . . . . . . . . . . . . . . . . . . . . Yes No

47 What was the reporting corporation’s share of reasonably anticipated benefits for the CSA? . . . . . . . . . %

48 a Enter the total amount of stock-based compensation deductions claimed by the reporting corporation . . . . . $

b Enter the total amount of deductions for the tax year for stock-based compensation that was granted during the term of the CSA 

and is directly identified with, or reasonably allocable to, the intangible development activity under the CSA . . . . . $

c Was there any stock-based compensation granted during the term of the CSA to individuals who performed functions in 

business activities that generate cost shared intangibles that was not treated as directly identified with, or reasonably 

allocable to, the intangible development activity? . . . . . . . . . . . . . . . . . . . . . Yes No

49a Enter the total amount of intangible development costs for the CSA . . . . . . . . . . . . . . . $

b Enter the amount of intangible development costs allocable to the reporting corporation based on the reporting corporation’s 

reasonably anticipated benefits share . . . . . . . . . . . . . . . . . . . . . . . . $

Part IX Base Erosion Payments and Base Erosion Tax Benefits Under Section 59A (see instructions)

50 Amounts defined as base erosion payments under section 59A(d) . . . . . . . . . . . . . . . . $

51 Amount of base erosion tax benefits under section 59A(c)(2) . . . . . . . . . . . . . . . . . $

52 Amount of total qualified derivative payments as described in section 59A(h) made by the reporting corporation . . $

53 Reserved for future use . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Form 5472 (Rev. 12-2023) 

a