Form 5472 due date, and what an extension changes

The date, and where it comes from

A single-member LLC owned by someone outside the US doesn’t file an income tax return of its own. Since 2017 the IRS treats it as a corporation for one narrow purpose: reporting the money that moves between the LLC and its owner. That report is Form 5472, and the Form 5472 instructions say it goes in attached to a pro forma Form 1120 “by the due date (including extensions) of that Form 1120.”

A Form 1120 is due on the 15th day of the fourth month after the tax year ends (Form 1120 instructions). The LLC uses the same tax year its owner uses for US filing, and if the owner has no US filing, the calendar year. For nearly every owner reading this, the year ends on December 31, so the date is April 15. If the 15th lands on a Saturday, Sunday or legal holiday, the IRS lets you file on the next business day.

• 2025 tax year: due April 15, 2026, or October 15, 2026 with an extension.
• 2026 tax year: due April 15, 2027, or October 15, 2027 with an extension.

What Form 7004 does

Form 7004 is the extension request. For a Form 1120 the extension is automatic and runs for six months. The IRS doesn’t send an approval. It only writes back if the request is disallowed (Form 7004 instructions).

For a foreign-owned LLC, the Form 5472 instructions add some details that the general Form 7004 instructions don’t mention:

• Enter the code for Form 1120 on Part I, line 1, because the Form 5472 rides on a pro forma 1120.
• Write “Foreign-owned U.S. DE” across the top of the Form 7004.
• Fax or mail it to the dedicated fax number or address in the Form 5472 instructions, not the regular Form 7004 address, by the original due date.

The last point catches people. The same instructions say a foreign-owned LLC “cannot file Form 5472 electronically,” so the return and the extension both go by fax or post to the IRS in Ogden, Utah. The fax number printed there today is 855-887-7737. Check the current instructions before you send anything, because numbers and addresses do change.

What the extension doesn’t change

The extension has to be on time. Form 7004 must be filed on or before the due date of the return it extends, so one sent in May doesn’t extend anything.

It only extends the time to file. The Form 7004 instructions say so directly: “Form 7004 does not extend the time to pay any tax due.” The pro forma 1120 itself asks for little more than the LLC’s name, address and two items on its first page, so there’s normally nothing to pay with it. If you owe US tax some other way, that date doesn’t move.

The penalty stays the same. The Form 5472 instructions put it at $25,000 for a reporting corporation that fails to file “when due and in the manner prescribed,” and a substantially incomplete form counts as not filed. After an extension, “when due” means October 15, and the same penalty applies from then.

Each Form 7004 covers one return. The instructions say to file a separate one for each return, so two LLCs need two extensions.

If April 15 already passed without an extension

Then October 15 isn’t your deadline. The return is late, and the useful thing to do is file it as soon as it’s complete and correct. The IRS can assess the penalty automatically when it processes a late Form 5472 attached to a late Form 1120 (Internal Revenue Manual 20.1.9.5.3). That’s why a late year usually goes in with a reasonable cause statement, and why it’s a different job from a current-year filing. We cover it on the late Form 5472 page.

A yearly calendar for the filing

Use January to gather what the filing needs: the EIN letter, the date the LLC was formed, and a list of every amount that moved between you and the LLC during the year. That list includes fees you paid for the LLC from your own card.

By the start of April, decide whether you’re filing or extending. If you extend, treat October 1 as your real deadline, so a failed fax or a missing document doesn’t push you past October 15.

If you’d rather not think about it at all, we prepare and file the pro forma 1120 and Form 5472 each year for a flat fee. Details are on the Form 5472 page.