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Any foreign-owned U.S. disregarded entity with reportable transactions with a related party during the tax year must file Form 5472 attached to a pro forma Form 1120.
A foreign-owned disregarded entity is a domestic entity, such as a single-member LLC, wholly owned by a foreign person, treated as a reporting corporation for information reporting purposes.
Reportable transactions include monetary and non-monetary exchanges such as sales, purchases, services, rents, royalties, loans, and interest with related parties.
The service includes preparing a pro forma Form 1120, completing Form 5472 to detail reportable transactions, and filing using dedicated DE submission procedures.
A foreign person includes non-resident individuals, foreign entities, certain foreign trusts or estates, and foreign governments engaged in commercial activity.