As a non-U.S. owner of a U.S. LLC, you have annual federal and state filing obligations. This checklist covers Form 5472, pro-forma Form 1120, FinCEN BOI, and state annual reports — with 2026 deadlines.
If you are a non-U.S. individual who owns a U.S. LLC, staying compliant requires filing multiple reports each year at the federal and state level. Most foreign founders are aware of the $25,000 Form 5472 penalty, but many are unaware of their other obligations. This checklist covers everything you need to file annually as a non-U.S. owner of a U.S. single-member LLC.
The most critical annual obligation for foreign-owned single-member LLCs is IRS Form 5472 with an attached pro-forma Form 1120. This information return must be filed even if the LLC had no revenue, as long as there were reportable transactions — which includes even basic owner capital contributions and withdrawals. Deadline: April 15 of the year following the tax year. Extension: 6 months available by filing Form 7004, pushing the deadline to October 15. Penalty for non-filing: $25,000 per form. How to file: By mail or fax to IRS Ogden Service Center, or use an automated service like ComplyWise ($29.99).
Under the Corporate Transparency Act, most U.S. LLCs must file a Beneficial Ownership Information (BOI) report with FinCEN. This report discloses the individuals who own or control the company. For LLCs formed before January 1, 2024, the initial filing deadline was January 1, 2025. For LLCs formed on or after January 1, 2024, the report must be filed within 90 days of formation. Updates are required within 30 days of any ownership changes. Note: As of early 2026, BOI reporting requirements are subject to ongoing legal challenges and regulatory updates. Verify current requirements with FinCEN or a qualified attorney. ComplyWise does not handle BOI filings.
Most U.S. states require LLCs to file an annual report (also called a Statement of Information or Annual Statement) and pay a fee. Requirements vary significantly by state. Delaware (popular with startups) requires a $300 annual franchise tax due June 1. Wyoming requires a small annual report fee. New Mexico has no annual report requirement. If you formed your LLC in Delaware through Stripe Atlas or Firstbase, you will typically need to file the Delaware annual report and franchise tax. State annual reports are separate from federal IRS filings. ComplyWise handles federal IRS filings only — not state annual reports.
Here are the key 2026 deadlines for most foreign-owned single-member LLCs. April 15, 2026: Form 5472 + pro-forma Form 1120 due (for 2025 tax year). June 1, 2026: Delaware annual franchise tax due (if LLC is a Delaware entity). October 15, 2026: Extended deadline for Form 5472 if Form 7004 was filed. Note that state annual report deadlines vary widely. Check your state's Secretary of State website for your specific deadline.
ComplyWise handles the federal IRS filing: Form 5472 and pro-forma Form 1120. It does not handle state annual reports, BOI filings, FBAR, income tax returns, or any other compliance obligations. For a standard non-U.S. founder with a single-member U.S. LLC, ComplyWise takes care of the most critical and penalty-heavy federal filing in 2-7 minutes for $29.99.
Do I need to file anything if my U.S. LLC had no revenue?
Yes. Form 5472 is required regardless of revenue, as long as there were reportable transactions — and virtually all active LLCs have at least one (even a capital contribution from the owner counts). The $25,000 penalty applies whether or not the LLC had income.
I formed my LLC through Stripe Atlas. What do I need to file each year?
If you formed a Delaware LLC through Stripe Atlas, your annual obligations typically include: IRS Form 5472 + pro-forma Form 1120 (federal, due April 15), Delaware annual franchise tax (state, due June 1), and possibly a FinCEN BOI report if you haven't filed one yet. Stripe Atlas does not handle these filings on your behalf.
Does Stripe Atlas file Form 5472 for me?
No. Stripe Atlas helps you form the LLC but does not file annual IRS compliance forms. You are responsible for filing Form 5472 and pro-forma Form 1120 each year. You can use ComplyWise to handle this federal filing for $29.99.
What happens if I miss the Form 5472 deadline?
The IRS will assess a $25,000 penalty per missed form. File as soon as possible if you are late — the penalty can sometimes be abated if you demonstrate reasonable cause. Do not wait, as additional penalties accrue for continued non-compliance.
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