Form 5472 §1.6038A-2 Attachment: Required Elements and Disclosure Examples

The "Other Transactions" Attachment — Surprisingly Important

The supplementary attachment under Treasury §1.6038A-2 has a misleadingly bland name ("other transactions"), but for foreign-owned U.S. disregarded entities (DEs), it's arguably more important than the structured Part IV line items.

For a typical foreign-owned single-member LLC, the monetary transactions on Part IV are often small or zero. The substance of the filing — the cross-border financial story the IRS actually cares about — lives in this attachment.

What Must Be Disclosed in the Attachment

Per the regulation, the attachment must include:

- **Amount paid or received** in the transaction - **Nature of the transaction** — what kind of transaction it was (capital contribution, loan, distribution, etc.) - **Identification of the related party** — by name and (if applicable) reference ID/TIN - **Sufficient factual detail** to make the transaction comprehensible to the IRS reviewer

The last element is the most subjective. "Sufficient factual detail" means enough context that a reader who knows nothing about your business can understand what happened. Not a one-liner; not a thesis; somewhere in between.

Why You Should Tell a Story, Not Just List Numbers

The video's framing: "I'm telling the story — I'm painting the picture for the IRS person who will look at this." This isn't a romantic flourish; it's practical advice.

IRS reviewers see thousands of Form 5472 attachments. The ones that get processed quickly without follow-up are the ones that read like a coherent narrative: what the LLC is, who the foreign owner is, what kinds of transactions happened, why they happened in business terms, and how the dollar amounts trace back to specific events. A pure data dump ("Transaction 1: $300, contribution; Transaction 2: $150, contribution") gets flagged for review because the reviewer can't see the bigger picture.

Apply to Every Transaction, Not Just the Big Ones

The attachment requirement applies to every reportable transaction, not just the largest ones. A $300 capital contribution to cover state franchise tax needs the same four elements (amount, nature, related party, factual detail) as a $300,000 capital injection.

For very small recurring transactions, you can summarize: "During the tax year, the foreign owner paid registered agent fees totaling $200 ($100 in March, $100 in September) on the LLC's behalf, treated as capital contributions." That captures all four elements without listing each transaction separately.

The Attachment Is Made by You (No IRS Template)

The IRS doesn't provide a template for this attachment. You create the document yourself, in plain text or PDF, with whatever formatting helps the reviewer.

A practical structure: title at the top ("Attachment to Form 5472 — Other Reportable Transactions Under §1.6038A-2"), tax year and reporting corporation name, EIN, then the body content. Add section headers if you have multiple transaction types. Sign and date at the bottom (same person who signed Form 1120 / Form 5472).

Practical Examples of Reportable "Other Transactions"

Examples that should always be reported in the attachment:

- **Formation costs paid by the owner** (Atlas, doola, attorney fees) — capital contribution - **State franchise tax paid by the owner personally** — capital contribution - **Registered agent fees paid by the owner** — capital contribution - **Owner advances funds for any business expense** — capital contribution or loan, depending on intent - **LLC distributes profits or excess capital back to owner** — distribution - **Dissolution payments back to owner** — distribution at dissolution - **In-kind transfers of equipment or intellectual property** — capital contribution (with valuation) - **Cross-border accommodations** (owner uses LLC's resources for personal use, or vice versa) — depending on facts