Can I File Form 5472 Without an ITIN? What Foreign LLC Owners Must Know (2026)

Yes — you can file Form 5472 without an ITIN. A foreign owner with no SSN or ITIN uses a reference ID number assigned by the LLC, or enters their foreign taxpayer identification number (FTIN) or “None”. The LLC itself must have an EIN, and the $25,000 penalty for not filing makes this form one you cannot skip.

What Is Form 5472?

Form 5472 is an IRS information return that reports transactions between a US company and its foreign owners or other related parties. An ITIN is an Individual Taxpayer Identification Number issued by the IRS to people who need a US tax ID but cannot get a Social Security Number. A foreign-owned US LLC — a single-member LLC owned by a non-resident — must file Form 5472 every year it has a reportable transaction with its owner.

What Do I Put on Form 5472 If I Have No ITIN?

Form 5472 asks for the foreign owner’s identifying number, but an ITIN is not the only acceptable answer. If you have no SSN and no ITIN, you can use a reference ID number — a number the LLC itself assigns to you for this purpose — or enter your foreign taxpayer identification number (FTIN), or write “None” where the form asks for it. The IRS accepts these alternatives because the form’s real purpose is identifying the related party, not forcing you to hold a US tax ID.

What you cannot skip is the LLC’s own EIN. An EIN is a US federal tax ID issued by the IRS. The LLC’s EIN goes on Form 5472 line 1b and on the pro forma Form 1120, item B. Non-residents get an EIN by faxing Form SS-4, which typically takes 12–18 days — so apply early, before the April 15 deadline.

How Do I File Form 5472 Without an ITIN?

Step 1: Get the LLC’s EIN. Without it, you cannot file at all. Fax Form SS-4 to the IRS and allow 12–18 days.

Step 2: Complete Form 5472. Fill in one Form 5472 for each related party — so one form per foreign owner. Report every reportable transaction with that person, including money you put into the LLC.

Step 3: Attach it to a pro forma Form 1120. A pro forma Form 1120 is a mostly blank corporate tax return filed only as a carrier for Form 5472. Fill in only the LLC’s name and address, item B (the EIN) and item E, and write “Foreign-owned U.S. DE” across the top. Nothing else on the 1120 is completed.

Step 4: File by fax or mail — you cannot e-file. Fax the package to 855-887-7737 at 300 DPI or higher, or mail it to the IRS Ogden PIN Unit, 1973 Rulon White Blvd, M/S 6112, Ogden, UT 84201. Keep proof of your fax transmission or mailing.

Step 5: Mind the deadline. Form 5472 is due April 15. File Form 7004 to extend the deadline to October 15.

What Counts as a Reportable Transaction?

Almost every money movement between you and your LLC counts. The classic first-year trap: the formation costs you paid out of your own pocket — the state filing fee, the registered agent fee, the formation service fee — count as a reportable transaction between you and the LLC. That is why the first year almost always needs a filing, even if the LLC earned nothing. Capital contributions, loans, payments for services and sales of property between you and the LLC are all reportable too.

What Is the Penalty for Not Filing Form 5472?

The penalty is $25,000 per form per year. If the IRS sends you a notice and you still do not file within 90 days, the penalty grows by another $25,000 for each 30-day period the failure continues. With one Form 5472 required per related party, a two-owner LLC that skips filing can face $50,000 in penalties for a single year. This is not a form to guess at — and unlike some IRS penalties, the Form 5472 penalty is not eligible for first-time abatement; only reasonable cause can remove it.

Do I Still Need an ITIN for Anything Else?

Yes, possibly. Filing Form 5472 does not require an ITIN, but you may still need one separately — for example, if you must file a personal US tax return (Form 1040-NR) to report your share of the LLC’s income. An ITIN application (Form W-7) costs $299 through Epics Deals, and processing typically takes about 7 weeks outside tax season, or 9–11 weeks during peak season or from abroad. Tax filing for your LLC starts from $120, and state tax filing from $60.

Epics Deals handles Form 5472 filings for non-resident and US-resident LLC owners alike — including the pro forma 1120, the fax filing and the deadline tracking.

Related: How Long Does It Take to Get an EIN? (2026)

Related: Single-Member vs Multi-Member LLC: Tax Differences Owners Must Know (2026)

Related: Delaware LLC Annual Tax 2026: The $400 Fee Explained

Frequently Asked Questions

Can I file Form 5472 without an ITIN? Yes. Use a reference ID number assigned by the LLC, your foreign taxpayer identification number (FTIN), or “None”. The LLC itself must still have an EIN.

Can I e-file Form 5472? No. Form 5472 cannot be e-filed. Fax it to 855-887-7737 (300 DPI or higher) or mail it to the IRS Ogden PIN Unit, 1973 Rulon White Blvd, M/S 6112, Ogden, UT 84201.

When is Form 5472 due? April 15 each year. File Form 7004 to extend the deadline to October 15.

What is the penalty for not filing Form 5472? $25,000 per form per year, plus another $25,000 for each 30-day period after 90 days from an IRS notice. One Form 5472 is required per related party.

Do I need to file Form 5472 in my LLC’s first year? Almost always, yes. Formation costs you paid personally count as a reportable transaction between you and the LLC, so a filing is usually required even if the LLC earned nothing.