What's New for 2026 Tax Year Foreign-Owned LLC Filings (Form 5472 & 1120)

Status of TY2026 Forms as of Spring 2026

As of April 2026 — just after the tax year 2025 filing deadline — the IRS has not yet published any TY2026 forms for foreign-owned LLC filers. The current published revisions are: Form 5472 rev. December 2023 (with instructions refreshed December 2024) and Form 1120 tax year 2025. No TY2026 drafts are posted on irs.gov/draft-tax-forms.

That means for the rest of 2026, any foreign-owned LLC that needs to file a return is still using TY2025 forms for catch-up or amended filings. The TY2026 cycle only starts when the IRS releases drafts — typically July through September.

What Usually Changes Year to Year

For foreign-owned single-member LLCs, the mechanics of Form 5472 + pro forma Form 1120 have been extremely stable since the December 2023 revision. Between tax years, the practical changes tend to be narrow:

• Form 1120 refreshes with updated line numbers, footnotes, or minor schedule changes — rarely anything that affects a foreign-owned disregarded entity filer • Instructions clarify language around reportable transactions, Part VI disclosures, or Part V transactions • Revenue Procedure (published October–November) adjusts inflation-indexed amounts: standard deduction, tax brackets, business mileage rate, Social Security wage base. Most of these do not apply to a pro forma 1120 filer with zero income, but they do apply to your personal return if you have any U.S.-source income.

Form 5472 itself changes infrequently. It last revised in December 2023, with instruction-only updates in December 2024. It is entirely possible TY2026 uses the same form with only refreshed instructions.

What Does NOT Change Year to Year

Three items that foreign LLC owners sometimes assume are year-indexed but are not:

• The $25,000 Form 5472 penalty — statutory under IRC §6038A and §6038C, unchanged since 2018. Congress would have to amend the code to change it. • The pro forma 1120 filing approach for disregarded entities — established in Treasury regulations, not re-evaluated yearly. • The Ogden, UT mailing address / fax number for Form 5472 — same destination every year.

If you see anyone claiming "the penalty has changed for 2026" or "the filing address is different this year," that is incorrect. Verify against the actual IRS instructions, not a third-party summary.

How to Prepare Now (April 2026)

If you own a foreign-owned LLC and want to be ready for the TY2026 filing season:

1. Keep clean records of every 2026 transaction as it happens — capital contributions, registered agent payments, LLC-paid expenses. The Transaction Categorizer at foreignllctax.com/tools helps tag transactions against Form 5472 Part IV and Part V categories. 2. Subscribe to the deadline reminder on the annual-reminder page so you get notified 30 days, 2 weeks, and 5 days before April 15, 2027. 3. Bookmark irs.gov/draft-tax-forms and check quarterly — TY2026 drafts typically appear by September 2026. 4. Do not pre-fill TY2026 returns using TY2025 forms. Wait for the final TY2026 version to release before generating the actual PDF.