Do you actually have to file?
Two conditions have to be true at the same time. Most of the confusion comes from checking one and assuming the other.
1. The ownership test
The entity is a US corporation or US LLC that is at least 25% foreign-owned, or a US disregarded entity whose owner is foreign. A single-member LLC owned by one non-US person is 100% foreign-owned, so it clears this test comfortably.
2. The transaction test
There was a reportable transaction with a related party during the year. For a one-owner LLC you are the related party, and everyday movements count:
- Money you contributed, including the initial funding
- Money you withdrew or distributed to yourself
- Amounts paid between the LLC and another company you own
- Loans in either direction between you and the LLC
“My LLC made no money, so there is nothing to report.” Revenue is not the test. If you funded the LLC’s bank account or paid its formation fee from your own pocket, that is a transaction with a related party, in a year with zero customers.
Cases that genuinely fall outside
An LLC formed and then never touched, with no bank account, no funding and no payments in or out, has no reportable transaction for that year. That is narrower than most people assume, and it stops applying the moment any money moves.
Multi-member LLCs are a different form
An LLC with two or more members is normally a partnership for US tax purposes and files Form 1065, not a pro forma 1120 with a 5472. Everything here is about the single-member, foreign-owned case.
Definitions follow the IRS Instructions for Form 5472. When your facts sit close to a line, that document and a qualified adviser beat any summary, including this one.