Record the scope decision before assembling forms
The IRS 5472 instructions define reporting corporations and reportable transactions and describe exceptions. A foreign-owned U.S. DE has special rules. Ask the reviewer to identify the taxpayer, classification, ownership, reporting year and applicable reporting requirement rather than inferring these from the EIN notice.
For a foreign-owned U.S. DE, the instructions describe a pro forma Form 1120 with Form 5472 attached; only the name/address and items B and E are required on that pro forma 1120. They specify the owner’s U.S. tax filing year or, if none, the calendar year. This limited pro forma treatment does not settle the owner’s other tax obligations.
Build the packet in five folders
- Scope: formation and ownership timeline, classification evidence, reviewer’s year and applicability conclusion, unresolved facts.
- Identity: exact legal name, address, EIN evidence and any later name/address updates. Cross-reference discrepancies rather than overwriting the original assignment.
- Related parties: one subfolder per party, relationship and identifying evidence, transaction IDs and supporting agreements/invoices. The instructions require a separate Form 5472 for each related party with reportable transactions.
- Reconciliation: transaction log, currency workpapers, accrual/cutoff adjustments, proposed categories and ties to books. Keep nonmonetary or less-than-full-consideration transactions visible for the applicable schedule review.
- Filing record: final signed complete copy and attachments, extension record if applicable, submission/receipt evidence and later correspondence. A draft packet belongs in a separate version.
Reconcile by party without deciding the tax labels
Fictional Cedar Example LLC’s file has a USD 2,000 owner transfer, a USD 300 formation invoice paid personally by the owner and a USD 500 repayment to the owner. The bank only shows the first and third events. The preparer receives all three source IDs, the invoice and payment evidence; the worksheet does not turn the USD 300 into “zero activity” because it bypassed the LLC bank.
Keep inflows and outflows separate. A USD 1,500 net bank movement is not an adequate substitute for the underlying events. The reviewer must establish the nature, related party, timing and reporting treatment. If a second related party exists, give it its own reconciliation rather than pooling all owners or companies.
Separate package completeness from filing
The foreign-owned U.S. DE instructions provide a dedicated fax/mail route and state that these filers cannot file Form 5472 electronically. Check the current instructions when acting; this page does not reproduce a destination or submit anything. Do not use the EIN application fax route.
Form 7004 preparation is a separate task and is not the 5472 filing. Retain the exact final package actually sent and its transmission evidence; delivery evidence is not a substantive IRS approval. The instructions treat a substantially incomplete Form 5472 as a failure to file and describe significant penalties, which is why unresolved content should be reviewed rather than filled with guesses.
Your private worksheet
Keep this record with your own source files. There is nothing to enter or upload here. Copy the headings, or open the plain-text sheet to save locally.
- Scope memo
- Taxpayer/classification, ownership, year, applicability conclusion, reviewer and source; unresolved questions.
- Party index
- Party ID, relationship support, identifying document location and separate transaction/subfolder references.
- Reconciliation
- Source IDs, gross inflows/outflows, nonbank events, nonmonetary transactions, currency and cutoff adjustments; proposed treatment for review.
- Package version
- Form revisions, complete page/attachment list, reviewer check and final copy identifier.
- Filing chain
- Extension separate; exact copy sent, method/date, delivery evidence and IRS correspondence; never label a draft filed.
Two fictional files to compare
Invented examples with no real applicant, taxpayer number or live account.
No sales, three owner events
Cedar’s sales report is empty but its owner funded formation and paid a bill.
Review result: Deliver the three-event reconciliation above. The reviewer decides reportability; no sales is not proof of no reportable transactions.
Only the 7004 receipt survives
Harbor has extension transmission evidence but no final 5472 packet.
Review result: Mark extension evidence present and final filing evidence missing. Recover the actual final copy and receipt instead of treating the extension as the return.
What completes this review?
The packet is review-ready when every proposed amount points to a source, each related party has its own index, and the remaining questions are explicit. It is filing-ready only after the responsible preparer completes the applicable review; this page does not certify that result.
Official sources
Checked November 4, 2026. A review date is not a form revision. Recheck current instructions and updates before acting; the worksheet is an organizational aid.