Form 5472 Attachment: Sample Disclosure for a Formation-Only Year (Stripe Atlas)

A Concrete Example: Just a Formation Contribution

Let's work through the simplest case: a foreign owner formed an LLC during the tax year using a service like Stripe Atlas, paid the formation fee personally, and had no other transactions for the rest of the year. The attachment can be very short.

The story: the LLC didn't exist yet when the formation fee was paid (no EIN, no bank account), so the foreign owner advanced the $250 service fee out of personal funds. The LLC didn't reimburse the owner. Under the typical accounting, this is a capital contribution.

Sample Disclosure Text

Here's a complete, ready-to-use disclosure for the formation-only scenario:

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Attachment to Form 5472 — Other Reportable Transactions Under Treasury Regulation §1.6038A-2

Report of Transactions of a Foreign Corporation That Is a Foreign-Owned U.S. Disregarded Entity

Tax Year: 2025

Reporting Corporation: [LLC Legal Name]

EIN: 12-3456789

Description of Reportable Transaction:

During the tax year, the sole foreign owner [Owner Name] paid $250 USD directly to Stripe Atlas on behalf of the LLC for formation services. This payment was made before the LLC obtained an EIN or opened a bank account. The LLC did not reimburse the owner for this payment. This payment is treated as a capital contribution under Treasury Regulation §1.6038A-2(b)(5).

No other reportable transactions occurred during this tax year.

Date: [Filing Date]

Signed: [Signature]

Name: [Owner Name]

Title: Owner

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That's a complete attachment for a no-activity LLC with only a formation cost. Short, specific, signed.

Including Registered Agent Fees in the Same Attachment

If the owner also paid registered agent fees during the year (typical $50–$200), expand the same attachment:

"During the tax year, the sole foreign owner [Name] paid $200 USD directly to [Registered Agent Service Name] on behalf of the LLC for registered agent services. This payment was made from personal funds without reimbursement and is treated as a capital contribution under §1.6038A-2(b)(5)."

Add this as a second paragraph under the description section. The structure stays the same; the volume of disclosure scales with the volume of transactions.

Date, Type, Amount — The Required Trinity

Each transaction needs the three core data points: date, type, amount. The video's framing: you already have the type (capital contribution) from the regulation, you need the date (when the payment happened) and the amount (in USD).

Dates can be specific ("July 15, 2025") or approximate ("during July 2025"). Amounts must be in USD, even if the underlying payment was in another currency — convert at the spot rate on the transaction date if needed.

For very small recurring payments (e.g., a $9/month bank account fee paid for 12 months), you can summarize as "total of $108 during 2025 in monthly bank fees" without listing each month.

Related Party: Sole Foreign Owner [Name]

Always identify the related party by their full name. "The sole foreign owner" alone isn't enough — the IRS wants the specific identity. "The sole foreign owner, [First Name Last Name], who is a citizen and tax resident of [Country]" is the gold standard.

If you have a reference ID number, you can include it: "the sole foreign owner, [Name] (Reference ID: WANG-LLC-25)." This ties the attachment to the Part II/Part III identification on the form itself.

Sign the Attachment, but No IRS Sign Field

Unlike Form 1120 (which has a structured signature field), the attachment has no IRS-defined signature field. You add the signature yourself at the bottom, with: date, signature, name, title.

The signature confirms the attachment is part of the filing under penalty of perjury — same legal weight as the main form's signature. Some practitioners skip the attachment signature; the IRS hasn't always enforced this, but the safe practice is to include it.

Attach to the Fax/Mail Package

If faxing, the attachment is just one of the pages in the assembled PDF you fax. Include it in the page sequence: pro forma Form 1120 (first), Form 5472 (next), attachment (last). The IRS fax intake system reads the whole package as one filing.

If mailing, the attachment is the last document in the envelope. Stack them in the same order: 1120, 5472, attachment. Use a paperclip or staple to keep them physically together; the IRS processing center sometimes shuffles loose pages.

No separate envelope or filing — the attachment travels with the main filing as a unified package.