Form 5472 报税表详解

外国人持股 25%+ 的美国公司必须提交的信息申报表

Form 5472 是 IRS 要求外国人持股 25% 以上的美国公司每年提交的信息申报表。不是缴税表，而是信息披露表——告诉 IRS 你和外国股东之间有哪些资金往来。未提交的罚款从 $25,000 起步且不封顶。即使公司没有收入、没有交易，只要有外国股东持股 25%+，就必须提交。

未提交罚款：$25,000 起步，每月递增，不封顶

Form 5472 随 Form 1120 一起提交。即使公司没有任何收入或交易，只要有外国人持股 ≥25%，就必须提交。逾期或未提交的罚款为 $25,000，之后每 30 天增加 $25,000，没有上限。

将鼠标悬停在税表中的任意一行或字段上，即可查看中文解释。中国创始人重点关注

Form5472(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

(Under Sections 6038A and 6038C of the Internal Revenue Code)

OMB No. 1545-0123

Part IReporting Corporation (see instructions). All reporting corporations must complete Part I.

1a Name of reporting corporation

1b Employer identification number

1c Total assets

Number, street, and room or suite no.

City or town, state, and ZIP code

1d Principal business activity

1e Principal business activity code

1f Total value of gross payments made or received reported on this Form 5472

1g Total number of Forms 5472

1m Date of incorporation

1l Country of incorporation

1n Country(ies) where files income tax return as resident

2 Check here if, at any time during the tax year, any foreign person owned, directly or indirectly, at least 50% of the total voting power or total value of stock ☐

Part II25% Foreign Shareholder (see instructions)

4a Name and address of direct 25% foreign shareholder

4b(1) U.S. identifying number, if any

4b(3) Foreign taxpayer identification number (FTIN), if any

4b(2) Reference ID number

4c Principal country(ies) where business is conducted

4d Country of citizenship, organization, or incorporation

4e Country(ies) where files income tax return as a resident

Form 5472 (Rev. 12-2023)

Form 5472 (Rev. 12-2023)Page 2

Part IIIRelated Party (see instructions). All reporting corporations must complete this question and the rest of Part III.

Check applicable box: Is the related party a ☐ foreign person or ☐ U.S. person?

8a Name and address of related party

8e Relationship — Check boxes that apply: ☐ Related to reporting corporation ☐ Related to 25% foreign shareholder ☐ 25% foreign shareholder

Part IVMonetary Transactions Between Reporting Corporation and Foreign Related Party (see instructions)

Amounts Received by Reporting Corporation (Lines 9-22)

9Sales of stock in trade (inventory)9

10Sales of tangible property other than stock in trade10

11Platform contribution transaction payments received11

12Cost sharing transaction payments received12

13aRents received (for other than intangible property rights)13a

bRoyalties received (for other than intangible property rights)13b

14Sales, leases, licenses, etc., of intangible property rights (for example, patents, trademarks, secret formulas)14

15Consideration received for technical, managerial, engineering, construction, scientific, or like services15

16Commissions received16

17Amounts borrowed: a Beginning balance / b Ending balance or monthly average17

18Interest received18

19Premiums received for insurance or reinsurance19

20Loan guarantee fees received20

21Other amounts received (see instructions)21

22Total. Combine amounts on lines 9 through 2122

Amounts Paid by Reporting Corporation (Lines 23-36)

23Purchases of stock in trade (inventory)23

24Purchases of tangible property other than stock in trade24

25Platform contribution transaction payments paid25

26Cost sharing transaction payments paid26

27aRents paid (for other than intangible property rights)27a

bRoyalties paid (for other than intangible property rights)27b

28Purchases, leases, licenses, etc., of intangible property rights (for example, patents, trademarks, secret formulas)28

29Consideration paid for technical, managerial, engineering, construction, scientific, or like services29

30Commissions paid30

31Amounts loaned: a Beginning balance / b Ending balance or monthly average31

32Interest paid32

33Premiums paid for insurance or reinsurance33

34Loan guarantee fees paid34

35Other amounts paid (see instructions)35

36Total. Combine amounts on lines 23 through 3536

Part VReportable Transactions of a Reporting Corporation That Is a Foreign-Owned U.S. DE (see instructions)

Describe on an attached separate sheet any other transaction and check here ☐

Part VINonmonetary and Less-Than-Full Consideration Transactions Between the Reporting Corporation and the Foreign Related Party

Describe these transactions on an attached separate sheet and check here ☐

Form 5472 (Rev. 12-2023)

Form 5472 (Rev. 12-2023)Page 3

Part VIIAdditional Information. All reporting corporations must complete Part VII.

#QuestionYes / No

37Does the reporting corporation import goods from a foreign related party?q37

38aIf “Yes,” is the basis or inventory cost of the goods valued at greater than the customs value of the imported goods?q38a

38bIf “Yes,” were the documents used to support this treatment of the imported goods in existence and available in the United States at the time of filing Form 5472?q38b

39During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?q39

40aDuring the tax year, did the reporting corporation pay or accrue any interest or royalty for which the deduction is not allowed under section 267A?q40a

41aIs the reporting corporation claiming a foreign-derived intangible income (FDII) deduction (under section 250) with respect to any transactions with the foreign related party?q41a

42aDid the reporting corporation have any loan to or from the related party to which the safe-haven rate rules are applicable, and for which the reporting corporation used a rate of interest within the relevant safe-haven range?q42a

42bDid the reporting corporation have any loan to or from the related party to which the safe-haven rate rules are applicable, and for which the reporting corporation used a rate of interest outside the relevant safe-haven range?q42b

43aDid the reporting corporation issue a covered debt instrument in any of the transactions described in Regulations section 1.385-3(b)(2) during the tax year with respect to a related party that is a corporation?q43a

Part VIIICost Sharing Arrangement (CSA)

Complete a separate Part VIII for each CSA. Most early-stage startups do not have a CSA.

Part IXBase Erosion Payments and Base Erosion Tax Benefits Under Section 59A (see instructions)

Applicable only to corporations with gross receipts of $500 million or more.

Form 5472 (Rev. 12-2023)

免责声明：本文仅为教育和信息目的，不构成税务、法律或会计建议。每家公司的税务情况不同，请咨询持牌的 CPA 或税务顾问获取专业建议。

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