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7/14/2025
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Trump's "One Big Beautiful Bill Act": Key Impacts for Foreign-Owned LLCs & Filers of Form 5472 or Form 1065
By Arik Rozen, CPA | Form5472.online
For non-U.S. residents who own Limited Liability Companies (LLCs) in the United States, regardless of the purpose—be it for investment, business operations, holding assets, or other reasons—a significant legislative event has occurred. The "One Big Beautiful Bill Act" (OBBBA), passed by the House on July 3, 2025, is expected to be signed into law by President Trump on July 4, 2025. While much of the bill focuses on domestic tax cuts, spending reductions, and border security, it does include specific provisions that directly impact foreign-owned U.S. entities and their reporting obligations, particularly for those dealing with Form 5472 and Form 1065.
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Guides - Form 5472 and IRS Filing
What is Form 5472 and Who Needs to File It?
As global business structures become more complex, the IRS is paying closer attention to international tax compliance. This makes understanding Form 5472 requirements incredibly important. The penalties for not filing are severe, reaching $25,000 per form each year, so knowing how to properly file and doing so on time is vital for your business.
Form 5472 Filing Deadlines and Penalties Explained
As foreign investment in U.S. businesses continues to rise, many owners face complex tax requirements, often only realizing them after receiving penalties from the IRS. Among these, Form 5472 stands out as a critical yet frequently misunderstood filing obligation for international business structures. This form is the IRS's main way to track transactions between foreign-owned U.S. corporations and their related parties, with penalties for non-compliance starting at $25,000.