Yes, you must file it for this case too. Fines are heavy. Here the relevant extracts from its instruction supporting my answer:Foreign-owned U.S. DEs(disregarded entities). While a foreign-owned U.S. DE has no income tax return filing requirement, as a result of final regulations under section 6038A, it will now be required to file a pro forma Form 1120 with Form 5472 attached by the due date (including extensions) of the return. The only information required to be completed on Form 1120 is the name and address of the foreign-owned U.S. DE and items B and E on the first page. The foreign-owned U.S. DE has the same tax year used by its owner for U.S. tax filing requirements or, if none, the calendar year. u201cForeign-owned U.S. DEu201d should be written across the top of Form 1120. File these forms by: u2024 Fax (300 DPI or higher) to 855-887-7737, or u2024 Mail to: Internal Revenue Service 1973 Rulon White Blvd M/S 6112 Attn: PIN Unit Ogden, Utah 84403Penalties for failure to file Form 5472. A penalty of $25,000 will be assessed on any reporting corporation that fails to file Form 5472 when due and in the manner prescribed. The penalty also applies for failure to maintain records as required by Regulations section 1.6038A-3.Note. Filing a substantially incomplete Form 5472 constitutes a failure to file Form 5472.