Form 5472 (Rev. December 2023), Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business Instructions

Check this box if, during the tax year, the reporting corporation became a participant in the cost sharing arrangement (CSA). Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Check this box if, during the tax year, the reporting corporation did not become a participant in the cost sharing arrangement (CSA). Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Provide a brief narrative description of the cost sharing arrangement (CSA) for which Part VIII is being completed. Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Check this box if the cost sharing arrangement (CSA) was in effect before January 5, 2009. Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Check this box if the cost sharing arrangement (CSA) was not in effect before January 5, 2009. Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Check this box if any amounts reported in Part IV are estimates rather than exact figures. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Check this box if the Form 5472 being filed is a consolidated filing (i.e., it reports multiple corporations together).

Check this box if this is the initial year the U.S. reporting corporation is filing Form 5472.

Enter Yes if this is a consolidated filing of Form 5472; otherwise enter No.

Enter the full legal name and complete mailing address (street, city, state/province, postal code, and country for foreign addresses) of the first direct 25% foreign shareholder.

Enter the U.S. identifying number (for example, EIN, SSN, or ITIN) for the first direct 25% foreign shareholder, if one exists.

Enter any reference ID number assigned to this shareholder as described in the instructions (leave blank if none).

Enter the shareholder's foreign taxpayer identification number (FTIN) issued by their country, if applicable.

Enter the principal country or countries where this shareholder conducts its business activities (list multiple countries separated by commas).

Enter the country of citizenship for an individual shareholder or the country of organization or incorporation for an entity.

Enter the country or countries under whose laws the shareholder files an income tax return as a resident (list multiple countries separated by commas).

Enter the full legal name and complete mailing address (street, city, state/province, and postal or ZIP code) of the first ultimate indirect 25% foreign shareholder.

Enter the U.S. taxpayer identifying number (for example, SSN, ITIN, or EIN) for the first ultimate indirect 25% foreign shareholder, if any.

Enter the reference ID number assigned to this shareholder per the form instructions (if applicable).

Enter the foreign taxpayer identification number (FTIN) for the first ultimate indirect 25% foreign shareholder, if one exists.

Enter the principal country or countries where the first ultimate indirect 25% foreign shareholder conducts its business.

Enter the country of citizenship for an individual or the country of organization or incorporation for an entity that describes the first ultimate indirect 25% foreign shareholder.

Enter the country or countries under whose laws the first ultimate indirect 25% foreign shareholder files an income tax return as a resident.

Enter the month and day on which the reporting corporation’s tax year begins.

Enter the year in which the reporting corporation’s tax year begins.

Enter the month and day on which the reporting corporation’s tax year ends.

Enter the year in which the reporting corporation’s tax year ends.

Enter the country where the corporation was legally incorporated.

Enter the date the corporation was legally incorporated.

Enter the country or countries under whose laws the reporting corporation files an income tax return as a resident.

Enter the country or countries where the corporation principally conducts its business activities.

Enter the total amount of intangible development costs for the cost sharing arrangement (CSA). Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Enter the amount of intangible development costs allocable to the reporting corporation based on its reasonably anticipated benefits share. Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Enter the total amount of sales of tangible property other than stock in trade (inventory) between the reporting corporation and the foreign related party for this line. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of platform contribution transaction payments received from the foreign related party for Line 11. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of cost sharing transaction payments received from the foreign related party for line 12. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of rents received from the related party for rents other than those for intangible property rights for the reporting period. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of royalties received from the related party during the tax year for property other than intangible property rights. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount received for sales, leases, licenses, or similar transfers of intangible property rights (such as patents, trademarks, or secret formulas) between the reporting corporation and the foreign related party. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of consideration received from the foreign related party for technical, managerial, engineering, construction, scientific, or similar services. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of commissions received from the foreign related party for this tax year. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the beginning balance of amounts borrowed from the foreign related party for line 17. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the ending balance or the monthly average balance of amounts borrowed from the foreign related party for line 17. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of interest received from the foreign related party for this line. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of premiums received from the foreign related party for insurance or reinsurance. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of loan guarantee fees received from the foreign related party during the tax year for line 20. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of other amounts received from the foreign related party for line 21. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount by combining the amounts reported on lines 9 through 21. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount paid to the foreign related party for purchases of stock in trade (inventory) during the tax year. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount paid for purchases of tangible property other than stock in trade (inventory) from the foreign related party for this line. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of platform contribution transaction payments paid to the foreign related party for this tax year. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of cost sharing transaction payments paid to the foreign related party for the tax year. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of rents paid to the foreign related party during the tax year for items other than intangible property rights. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of royalties paid to the foreign related party for items other than intangible property rights. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount paid for purchases, leases, licenses, or similar transactions involving intangible property rights (such as patents, trademarks, or secret formulas) with the foreign related party. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of consideration paid to the related party for technical, managerial, engineering, construction, scientific, or similar services. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of commissions paid to the foreign related party during the tax year. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the beginning balance for amounts loaned to the related party for line 31. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the ending balance (or, if required, the monthly average) for amounts loaned to the related party for line 31. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of interest paid to the foreign related party for this reporting period. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of premiums paid for insurance or reinsurance to the foreign related party for line 33. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of loan guarantee fees paid to the foreign related party during the tax year. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of other payments made to the foreign related party that are not reported on lines 23 through 34. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount for line 36 by combining the amounts reported on lines 23 through 35. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Enter the total amount of sales of stock in trade (inventory) in monetary transactions between the reporting corporation and the foreign related party. Fill only if 'Is the related party a foreign person or U.S. person?' is 'Foreign person'.

Check this box if, at any time during the tax year, any foreign person owned, directly or indirectly, at least 50% of the reporting corporation's total voting power or the total value of all classes of its stock.

Check this box if the reporting corporation is a foreign-owned domestic disregarded entity (foreign-owned U.S. DE) that is treated as a corporation for purposes of section 6038A.

Enter the reporting corporation’s total assets for the tax year.

Enter the total value of gross payments made or received that are reported on this Form 5472.

Enter the total number of Forms 5472 filed for the tax year.

Enter the total value of gross payments made or received that are reported on all Forms 5472 for the tax year.

Check this box if any direct (or ultimate indirect) 25% foreign shareholder listed in Part II is a surrogate foreign corporation under section 7874(a)(2)(B).

Enter the total amount defined as base erosion payments under section 59A(d).

Enter the total amount of base erosion tax benefits under section 59A(c)(2).

Enter the total amount of qualified derivative payments described in section 59A(h) made by the reporting corporation.

Leave this box unchecked because line 53 is reserved for future use and is not intended to be completed.

Check this box if you are attaching a separate sheet describing other reportable transactions (for example, formation, dissolution, acquisition, disposition, contributions to, or distributions from the entity) as defined by the instructions. Fill only if 'the reporting corporation is a foreign-owned domestic disregarded entity (foreign-owned U.S. DE) treated as a corporation for purposes of section 6038A' is 'Yes'.

Check this box if you are describing nonmonetary and less-than-full consideration transactions between the reporting corporation and the foreign related party on an attached separate sheet.

Enter a short, descriptive name of the reporting corporation's principal business activity (for example, "Manufacturing — automotive parts" or "Software development").

Provide the principal business activity code (such as the applicable NAICS or other classification code) that corresponds to the business activity entered in Principal business activity.

Check this box if the reporting corporation imports goods from a foreign related party.

Check this box if the reporting corporation does not import goods from a foreign related party.

Check this box if the basis or inventory cost of the imported goods is valued at greater than the customs value. Fill only if 'Yes' is 'Yes'.

Check this box if the basis or inventory cost of the imported goods is not valued at greater than the customs value. Fill only if 'Yes' is 'Yes'.

Check this box if the documents used to support the treatment of imported goods were in existence and available in the United States at the time of filing Form 5472. Fill only if 'Yes', 'Yes' are all 'Yes'.

Check this box if the documents used to support the treatment of imported goods were not in existence or not available in the United States at the time of filing Form 5472. Fill only if 'Yes', 'Yes' are all 'Yes'.

Check this box if, during the tax year, the foreign parent corporation participated in any cost sharing arrangement (CSA).

Check this box if, during the tax year, the foreign parent corporation did not participate in any cost sharing arrangement (CSA).

Check this box if, during the tax year, the reporting corporation paid or accrued any interest or royalty for which the deduction is not allowed under section 267A.

Check this box if, during the tax year, the reporting corporation did not pay or accrue any interest or royalty for which the deduction is not allowed under section 267A.

Enter the total amount of interest and/or royalty deductions that are disallowed under section 267A for the tax year. Fill only if 'Yes' is 'Yes'.

Check this box if the reporting corporation is claiming a foreign-derived intangible income (FDII) deduction under section 250 with respect to any transactions with a foreign related party.

Check this box if the reporting corporation is not claiming a foreign-derived intangible income (FDII) deduction under section 250 with respect to transactions with a foreign related party.

Enter the total gross receipts from sales of general property to the foreign related party that were included in the corporation’s FDDEI calculation. Fill only if 'Q41a – Yes (Claiming FDII deduction for transactions with foreign related party)' is 'Yes'.

Enter the total gross receipts from sales of intangible property to the foreign related party that were included in the corporation’s FDDEI calculation. Fill only if 'Q41a – Yes (Claiming FDII deduction for transactions with foreign related party)' is 'Yes'.

Enter the total gross receipts from services provided to the foreign related party that were included in the corporation’s FDDEI calculation. Fill only if 'Q41a – Yes (Claiming FDII deduction for transactions with foreign related party)' is 'Yes'.

Check this box if the reporting corporation had a loan to or from the related party subject to the safe-haven rate rules and used an interest rate within the relevant safe-haven range (100%–130% of the applicable AFR) for the relevant term.

Check this box if the reporting corporation did not have any such loan subject to the safe-haven rate rules with an interest rate within the relevant safe-haven range (100%–130% of the applicable AFR) for the relevant term.

Check this box if the reporting corporation had a loan to or from the related party subject to the safe-haven rate rules and used an interest rate outside the relevant safe-haven range.

Check this box if the reporting corporation did not have such a loan with an interest rate outside the relevant safe-haven range.

Check this box if the reporting corporation issued a covered debt instrument or issued/refinanced related-party indebtedness within the 36-month window described in Regulations section 1.385-3(b) during the tax year.

Check this box if the reporting corporation did not issue a covered debt instrument and did not issue/refinance the related-party indebtedness described in Regulations section 1.385-3(b) during the tax year.

Enter the total dollar amount of the related transactions, distributions, and acquisition(s) reported for question 43a. Fill only if 'Q43a - Yes' is 'Yes'.

Enter the total dollar amount of such related party indebtedness for question 43a. Fill only if 'Q43a - Yes' is 'Yes'.

Enter the reporting corporation’s share of the reasonably anticipated benefits for the cost sharing arrangement (CSA) as a percentage. Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Enter the principal country or countries where the related party conducts its business.

Enter the country or countries under whose laws the related party files an income tax return as a resident.

Enter the related party’s U.S. identifying number, if any.

Enter the reference ID number for the related party as instructed.

Enter the related party’s foreign tax identifying number, if any.

Enter the full legal name and complete mailing address of the related party.

Check this box if the related party is a foreign person.

Check this box if the related party is a U.S. person.

Enter the related party’s principal business activity.

Enter the code that corresponds to the related party’s principal business activity.

Check this box if the related party is related to the reporting corporation.

Check this box if the related party is related to a 25% foreign shareholder of the reporting corporation.

Check this box if the related party is a 25% foreign shareholder of the reporting corporation.

Enter the full legal name of the reporting corporation as registered with the IRS.

Enter the reporting corporation's street address including building number and room or suite information; if using a P.O. box, follow the form instructions.

Enter the city or town, U.S. state (or foreign province) and ZIP or postal code for the reporting corporation's address.

Enter the reporting corporation's Employer Identification Number issued by the IRS.

Enter the full legal name and mailing address (street, city, state/province, postal code, and country) of the second direct 25% foreign shareholder.

Enter the U.S. identifying number (TIN or EIN) for the second direct 25% foreign shareholder, if the shareholder has one; otherwise leave blank.

Enter any reference identification number assigned to this shareholder as described in the form instructions (leave blank if none).

Enter the foreign taxpayer identification number issued by the shareholder's country of residence, if any; otherwise leave blank.

Enter the name of the country where the second direct 25% foreign shareholder principally conducts its business.

Enter the country (or countries) of the shareholder's citizenship, organization, or incorporation.

Enter the country under whose laws the second direct 25% foreign shareholder files an income tax return as a resident.

Enter the full legal name and mailing address (street address, city, state/province, and ZIP/postal code) of the second ultimate indirect 25% foreign shareholder.

Enter the U.S. taxpayer identification number (for example, EIN or SSN) for this shareholder, if one exists.

Enter the reference ID number assigned to this shareholder as described in the form instructions, if applicable.

Enter the foreign tax identifying number (FTIN) issued to the shareholder by its country of residence, if any.

Enter the principal country or countries in which the shareholder conducts its business.

Enter the country of the shareholder's citizenship or the country where the shareholder is organized or incorporated.

Enter the country or countries under whose laws the shareholder files an income tax return as a resident.

Enter the total amount of stock-based compensation deductions claimed by the reporting corporation for the tax year. Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Enter the total stock-based compensation deductions for the tax year for awards granted during the term of the CSA that are directly identified with, or reasonably allocable to, the intangible development activity under the CSA. Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Check this box if any stock-based compensation was granted during the CSA term to individuals performing cost-shared intangible development functions and it was not treated as directly identified with, or reasonably allocable to, the intangible development activity. Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.

Check this box if no stock-based compensation was granted during the CSA term to such individuals that was not treated as directly identified with, or reasonably allocable to, the intangible development activity. Fill only if 'During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?' is 'Yes'.