Form 5472 Part VI — do I need to attach a statement about the owner being the manager?
My CPA added an extra attachment to my Form 5472 filing labeled 'Part VI' that says 'THE FOREIGN RELATED PARTY IS THE MEMBER MANAGER OF THE REPORTING CORPORATION.' He told me this discloses the nonmonetary relationship between me (the sole owner) and the LLC, since I'm also the manager.
But another CPA I talked to said he never adds this — he only attaches the Part V statement about the actual monetary transactions (like the setup fee and capital contributions). He says Part VI is only needed if there were actual nonmonetary exchanges of value.
My LLC was just formed this year. The only transaction was a $300 formation fee. No real business operations yet. Which CPA is right? Do I need this Part VI attachment?
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