Country guide

Form 5472 for Pakistani-Owned US LLCs (2026)

Quick answer

If you're a Pakistani founder with a US single-member LLC, you generally must file Form 5472 + a pro-forma 1120 every year, even at $0 tax. Failing to file Form 5472 when due and in the manner prescribed carries a $25,000 penalty.[1] A US–Pakistan tax treaty exists (a separate question from this filing), and you should confirm FBR/SBP treatment of foreign income with a local advisor. (US filing: HIGH. Pakistan side: NEEDS LOCAL EXPERT REVIEW.)

Key facts

  • A foreign-owned U.S. disregarded entity has no income tax return filing requirement of its own, but must still file a pro forma Form 1120 with Form 5472 attached by that Form 1120's due date.[2]
  • Failing to file Form 5472 when due and in the manner prescribed carries a $25,000 penalty.[1]
  • US–Pakistan treaty exists (affects tax, not the filing duty). HIGH
  • FBR treatment of foreign income and any SBP disclosure. Confirm with an advisor. NEEDS LOCAL EXPERT REVIEW

What this means for you (Pakistan)

Treat the annual 5472 as a fixed cost of owning the LLC, separate from US tax. On the Pakistan side, ask your advisor how foreign-source income is taxed by the FBR and whether any SBP disclosure applies.

Frequently asked questions

Do I file 5472 even with no income?

Generally yes. HIGH

Does the treaty remove the filing?

No. HIGH

What do I ask my advisor?

FBR foreign-income treatment + SBP disclosure.

Sources used

  • IRS, Instructions for Form 5472: irs.gov · IRS Treaties A–Z (Pakistan listed)
  • SBP / FBR (Pakistan block, reviewed locally)

Sources

  1. [1]Internal Revenue Service, Instructions for Form 5472 (12/2024) — A penalty of $25,000 will be assessed on any reporting corporation that fails to file Form 5472 when due and in the manner prescribed. (retrieved )
  2. [2]Internal Revenue Service, Instructions for Form 5472 (12/2024) — While a foreign-owned U.S. DE has no income tax return filing requirement, as a result of final regulations under section 6038A, it will now be required to file a pro forma Form 1120, U.S. Corporation Income Tax Return, with Form 5472 attached by the due date (including extensions) of that Form 1120. (retrieved )

Related

US tax and Pakistan-side reporting depend on your facts. Confirm with a US CPA and a Pakistani advisor. See the Pakistan guide and Form 5472 guide.

Last updated: September 1, 2026.

Next step

Get a compliance review with Prolify to map what your Pakistani-owned LLC must file.

Start your US companySee pricing