5471 vs 5472
One is filed about a foreign corporation you own; the other about a US corporation a foreigner owns. The direction of ownership is the whole difference.
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One is filed about a foreign corporation you own; the other about a US corporation a foreigner owns. The direction of ownership is the whole difference.
Side by side
| Form 5471 | Form 5472 | |
|---|---|---|
| Reports | A US person's interest in a foreign corporation | A US corporation's transactions with related foreign parties |
| Typical filer | A US founder who incorporated abroad | A foreign group's US subsidiary, or a foreign-owned US LLC |
| Content | Ownership, income statement, balance sheet, intercompany items | Reportable transactions with related foreign parties |
| Dormant entity | Still reportable in most categories | Still reportable — the classic forgotten LLC |
| Penalty | Per form, per year | Per form, per year |
Which one applies to you
Ask which way the ownership runs. US person owning abroad points at the first form; foreign person owning a US entity points at the second. A group with both directions files both.
How to get this moving
The first call establishes whether there is work to do. Everything after that is quoted.
Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
International tax accountant — what this page covers
Readers arrive here searching for international tax accountant, and Form 5471 vs 5472 is what the page is about. Below: who it catches, what has to be filed, and what it costs — quoted in writing, before anything is done.
Why choose Legal Quotient for 5471 vs 5472
Filed with the authority, not just prepared
The engagement runs to submission and to the correspondence that follows it, including the queries that arrive months later.
Every figure on a page is traceable
Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.
Cross-border is the whole practice
International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.
We say early if it is not our work
If a file needs something this practice does not do, you hear that at the start rather than after a bill.
What these engagements turn on
A founder who incorporated abroad and reported nothing at home
The client had built a company overseas while holding US citizenship and treated the two facts as unrelated. They are not. We established the category of filer from the shareholding and the way it had been acquired, then restated the company's accounts into the format the form requires, which is the step that takes the time because local accounts are never prepared on that basis. The engagement produced reporting for the open years with the ownership history documented, and a standing schedule so the filing now follows the company's own year end.
The forgotten US company owned from outside the country
A dormant limited liability company, formed years earlier for a venture that never started, surfaced when the owner tried to close it. Because the owner is foreign and the entity American, the reporting obligation had been running quietly the whole time. We rebuilt the position from the bank records, identifying the funding and the payments made on the entity's behalf as the reportable items they are. The work produced a filed set of late returns with the history documented, after which the company was wound up on a clean footing.
A group that needed both forms in the same year
An acquisition left the group owning a foreign company through a US holding entity while a foreign parent still held part of the American side. Ownership ran in both directions, so both reporting regimes applied at once. We mapped the shareholdings entity by entity onto a single page, marked the direction each line ran, and built the filing list from that map rather than from the organisation chart. The engagement produced a documented filing matrix, the returns for the year under both regimes, and an agreed test to re-run the matrix after any share transfer.
Reclassifying filings made on the wrong form
The client had been filing conscientiously and on the wrong form, having read the ownership as running the other way. The underlying facts were not in dispute; the characterisation was. We set out the ownership chain in writing, established which party was the US person and which the foreign one, and corrected the position for the open years. The work produced filings on the correct form, a memorandum explaining how the original reading arose, and a short test the client's bookkeeper now applies whenever a new entity joins the group.
Ownership that changed direction partway through the year
A share sale turned a foreign-owned US company into a US-owned group with a foreign subsidiary, and the client assumed the new position applied to the whole year. It did not. We split the year at the transaction date, established what each regime required on either side of it, and documented the transaction itself as the hinge. The engagement produced filings covering both parts of the year, the ownership change evidenced by the sale documents rather than asserted, and a written note of what the following year will require.
Reporting uncovered during a buyer's due diligence
A buyer's advisers asked for the last several years of information returns and the seller had none to give. We were brought in on the seller's side, with a deadline someone else had set. The work consisted of establishing the filing obligations entity by entity, restating accounts that had never been prepared for this purpose, and filing the open years with explanations attached. The engagement produced a documented compliance history the buyer's advisers accepted, and the disclosure schedule in the sale agreement was rewritten to reflect what had been filed.
A Canadian Working in the US on a Work Visa
Immigration status and tax residence are different tests, and a visa says nothing about which country taxes the salary. The file fixes residence, applies the employment article, and sequences the two returns so the credit lands where it is usable.
Read how this one runsDeemed Resident or Factual Resident — Not the Same File
The two statuses attract different returns, different credits and different provincial treatment, and the label is decided by facts rather than chosen. Establishing which applies is the work; the filing follows from it without argument.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
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Strategy and compliance for income, assets and families spread across borders.
U.S. & Cross-Border Tax Returns
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Transfer Pricing & BEPS
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Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
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Technology & SaaS
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Professional Services Firms
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Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
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Athletes, Artists & Entertainers
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Remote Workers & Digital Nomads
- Residency analysis before moving
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Investment Funds & Holding Companies
Holding structures live or die on treaty access, beneficial ownership and substance — the MLI's principal-purpose test now sits over every arrangement.
A holding structure is only as good as its reporting. Foreign affiliates, accrued passive income and distributions each carry their own return, and the penalties on those attach to the form rather than to any tax being owed — so a structure that saves tax can still cost money if the information returns are late.
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
