What counts as a "related-party transaction" for Form 5472 purposes?

Yes — even with zero transactions, you must file a Form 5472 to report that there were no reportable transactions. The "negative" filing is mandatory.

Beyond the zero-transaction case, related-party transactions include a surprisingly broad range of activities.

Statutory definition (Reg. §1.6038A-2(b)(3)):

A reportable transaction is any transaction listed in the regulation between the reporting corporation and a related party. The list is exhaustive.

Categories of reportable transactions:

Specific transactions to watch:

1. Capital contributions. When you fund the LLC by putting money in, that's a reportable transaction. Even the initial funding to start the LLC.

1. Loans. Any loan between you and the LLC, in either direction. Even a temporary "I'll cover the LLC's expenses out of my personal account" arrangement.

1. Reimbursements. If you pay an LLC expense personally and the LLC reimburses you, that's reportable.

1. Services. If you provide services to the LLC (even without invoicing), the imputed value can be reportable. The regs are murky on services without formal billing.

1. Property transfers. Transferring a car, computer, real estate, or any property to/from the LLC.

1. Distributions. Taking money out of the LLC (even for personal use, even via casual transfers).

1. Forgiveness of debt. If the LLC owes you money and you forgive the debt, that's reportable.

Common "I didn't do anything" cases that still trigger filing:

• "I just made the LLC; I haven't had any business yet." → Initial capital contribution to start the LLC is reportable. File a $0-otherwise Form 5472 reflecting that contribution.

• "I bought a rental property through the LLC but had no income/expenses in year 1." → Initial property purchase via LLC, with funding from you, is reportable. File showing the capital contribution.

• "The LLC bank account just sits there empty." → If you opened the account, you presumably funded it. Initial deposit is reportable.

What's NOT reportable:

• Personal transactions outside the LLC (you buying groceries with your personal money)
• Transactions where the related party is NOT a 25%+ owner or related to a 25%+ owner
• Transactions in foreign currency below de minimis thresholds — though these still appear on the form, just at $0

The zero-transaction filing:

When there genuinely are no reportable transactions for the year, you file Form 5472 with:

• Part II: Foreign owner identification (still required)
• Parts III through VII: All zeros or blank

This is a real, valid Form 5472 — just one showing $0 across the categories. The form must still be filed; failure to do so triggers the $25,000 penalty.

Worked example — typical first-year LLC:

Foreign individual creates US LLC in 2024 to hold a rental property they're about to buy. In 2024:

• January 5: Forms LLC. Fees $500 paid via the foreign owner's personal credit card.
• January 12: Foreign owner wires $200,000 to the LLC bank account to fund the property purchase.
• February 15: LLC purchases rental property for $195,000 (paying closing costs from the wired $200K).
• No tenant yet in 2024. No rental income.
• $5,000 remaining in LLC bank account.

Reportable transactions for 2024:

• Capital contribution: $200,000 (the wire)
• Reimbursement: $500 (the formation fees, if the LLC reimburses the foreign owner)

So the Form 5472 reports a $200,000 capital contribution under the appropriate category. Total transactions: ~$200,000. The 5472 is NOT empty.

For the EA exam:

Know:

• Filing is required even with zero transactions (negative filing required)
• "Reportable transactions" is broadly defined to include capital contributions, loans, services, reimbursements
• Initial LLC funding is a reportable transaction
• Penalty applies even for negative filings missed

This is one of the highest-test-frequency international tax topics on the EA Part 1 exam.