Per Form 5472 Instructions, generally, a reporting corporation must file Form 5472 if it had a reportable transaction with a foreign or domestic related party
A reporting corporation is either:
- A 25% foreign-owned U.S. corporation (including a foreign-owned U.S. disregarded entity (DE)), or
- A foreign corporation engaged in a trade or business within the United States.
A reportable transaction is:
- Any type of transaction listed in Part IV (for example, sales, rents, etc.) for which monetary consideration (including U.S. and foreign currency) was the sole consideration paid or received during the reporting corporation’s tax year; or
- Any transaction or group of transactions listed in Part IV, if:
- 1. Any part of the consideration paid or received was not monetary consideration, or
- 2. Less than full consideration was paid or received. Transactions with a U.S. related party, however, are not required to be specifically identified in Parts IV and VI.
There are exceptions to reporting see page 1 of Form 5472 Instructions.
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