Information Return of a 25% Foreign-Owned U.S. Corporation or a 
Form  5472                      Foreign Corporation Engaged in a U.S. Trade or Business 
(Rev. December 2023)             (Under Sections 6038A and 6038C of the Internal Revenue Code)                                          OMB No. 1545-0123 
                                     Go to www.irs.gov/Form5472 for instructions and the latest information.
Department of the Treasury  For tax year of the reporting corporation beginning           ,       , and ending                 , 
Internal Revenue Service               Note: Enter all information in English and money items in U.S. dollars. 
Part I        Reporting Corporation (see instructions). All reporting corporations must complete Part I. 
1a  Name of reporting corporation                                                                                        1b  Employer identification number

     Number, street, and room or suite no. (If a P.O. box, see instructions.)                                            1c  Total assets 

     City or town, state, and ZIP code (If a foreign address, see instructions.)
                                                                                                                         $ 
1d  Principal business activity                                                                       1e  Principal business activity code 
1f   Total value of gross payments made or received        1g  Total number of Forms 5472             1h  Total value of gross payments made or received 
     reported on this Form 5472. See instructions.             filed for the tax year                     reported on all Forms 5472. See instructions. 
$                                                                                                      $ 
1i   Check here if this is a    1j   Check here if this is the initial year for       1k  Total number of Parts VIII     1l  Country of incorporation 
     consolidated filing of          which the U.S. reporting corporation                 attached to Form 5472 
     Form 5472      .    .           is filing a Form 5472 .     .     .        .
1  m Date of incorporation      1n  Country(ies) under whose laws the reporting                    1o  Principal country(ies) where business is conducted
                                     corporation files an income tax return as a resident

2    Check here if, at any time during the tax year, any foreign person owned, directly or indirectly, at least 50% of (a) the total voting power of all 
     classes of the stock of the reporting corporation entitled to vote, or (b) the total value of all classes of stock of the reporting corporation  .      
3    Check here if the reporting corporation is a foreign-owned domestic disregarded entity (foreign-owned U.S. DE) treated as a corporation for 
     purposes of section 6038A. See instructions     .   . .     .     .        . . . .   . .   .  .   .  . .    .   .   .   .   . .  .   . .    . .  .
Part II       25% Foreign Shareholder (see instructions)
              Check here if any direct (or ultimate indirect) 25% foreign shareholder listed in Part II is a surrogate foreign 
              corporation under section 7874(a)(2)(B). 
4a  Name and address of direct 25% foreign shareholder 

4b(1)  U.S. identifying number, if any 4b(2)  Reference ID number (see instructions)            4b(3)  Foreign taxpayer identification number (FTIN), if any 
                                                                                                       (see instructions)

4c  Principal country(ies) where       4d  Country of citizenship,                    4e  Country(ies) under whose laws the direct 25% foreign 
     business is conducted                 organization, or incorporation                   shareholder files an income tax return as a resident 

5a  Name and address of direct 25% foreign shareholder 

5b(1)  U.S. identifying number, if any 5b(2)  Reference ID number (see instructions)            5b(3)  FTIN, if any (see instructions)

5c  Principal country(ies) where       5d  Country of citizenship,                    5e  Country(ies) under whose laws the direct 25% foreign 
     business is conducted                 organization, or incorporation                   shareholder files an income tax return as a resident 

6a  Name and address of ultimate indirect 25% foreign shareholder 

6b(1)  U.S. identifying number, if any 6b(2)  Reference ID number (see instructions)            6b(3)  FTIN, if any (see instructions)

6c  Principal country(ies) where       6d  Country of citizenship,                    6e  Country(ies) under whose laws the ultimate indirect 25% foreign 
     business is conducted                 organization, or incorporation                   shareholder files an income tax return as a resident 

7a  Name and address of ultimate indirect 25% foreign shareholder 

7b(1)  U.S. identifying number, if any 7b(2)  Reference ID number (see instructions)            7b(3)  FTIN, if any (see instructions)

7c  Principal country(ies) where       7d  Country of citizenship,                    7e  Country(ies) under whose laws the ultimate indirect 25% foreign 
     business is conducted                 organization, or incorporation                   shareholder files an income tax return as a resident 

For Paperwork Reduction Act Notice, see instructions.                                     Cat. No. 49987Y                             Form 5472 (Rev. 12-2023) 

Form 5472 (Rev. 12-2023)                                                                                                                           Page  2 
Part III       Related Party (see instructions). All reporting corporations must complete this question and the rest of Part III.
               Check applicable box: Is the related party a                 foreign person or         U.S. person?
8a  Name and address of related party 

8b(1)  U.S. identifying number, if any   8b(2)  Reference ID number (see instructions)     8b(3)  FTIN, if any (see instructions)

8c  Principal business activity                                                                  8d  Principal business activity code
8e  Relationship—Check boxes that apply:         Related to reporting corporation      Related to 25% foreign shareholder        25% foreign shareholder
8f   Principal country(ies) where business is conducted             8g  Country(ies) under whose laws the related party files an income tax return as a 
                                                                        resident 

Part IV        Monetary Transactions Between Reporting Corporations and Foreign Related Party (see instructions)
               Caution: Part IV must be completed if the “foreign person” box is checked in the heading for Part III.            
               If estimates are used, check here. 
9      Sales of stock in trade (inventory)  . .  . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     9
10     Sales of tangible property other than stock in trade  .  .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     10
11     Platform contribution transaction payments received      .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     11
12     Cost sharing transaction payments received  .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     12
13a    Rents received (for other than intangible property rights)   .   . . .    .   .  .  . .    .   . . .     .   . .    .     13a
b      Royalties received (for other than intangible property rights)   . . .    .   .  .  . .    .   . . .     .   . .    .     13b
14     Sales, leases, licenses, etc., of intangible property rights (for example, patents, trademarks, secret formulas)  . .     14
15     Consideration received for technical, managerial, engineering, construction, scientific, or like services  . . .    .     15
16     Commissions received  .    .    .    . .  . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     16
17     Amounts borrowed (see instructions) a  Beginning balance                      b  Ending balance or monthly average        17b
18     Interest received  .  .  . .    .    . .  . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     18
19     Premiums received for insurance or reinsurance  .  .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     19
20     Loan guarantee fees received  .      . .  . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     20
21     Other amounts received (see instructions) . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     21
22     Total. Combine amounts on lines 9 through 21  .    .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     22
23     Purchases of stock in trade (inventory) . . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     23
24     Purchases of tangible property other than stock in trade     .   . . .    .   .  .  . .    .   . . .     .   . .    .     24
25     Platform contribution transaction payments paid .  .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     25
26     Cost sharing transaction payments paid  .   .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     26
27a    Rents paid (for other than intangible property rights) . .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     27a
b      Royalties paid (for other than intangible property rights) . .   . . .    .   .  .  . .    .   . . .     .   . .    .     27b
28     Purchases, leases, licenses, etc., of intangible property rights (for example, patents, trademarks, secret formulas)      28
29     Consideration paid for technical, managerial, engineering, construction, scientific, or like services  . .   . .    .     29
30     Commissions paid      .  . .    .    . .  . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     30
31     Amounts loaned (see instructions)   a  Beginning balance                      b  Ending balance or monthly average        31b
32     Interest paid     . . .  . .    .    . .  . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     32
33     Premiums paid for insurance or reinsurance  .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     33
34     Loan guarantee fees paid   .    .    . .  . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     34
35     Other amounts paid (see instructions)  .  . .    . .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     35
36     Total. Combine amounts on lines 23 through 35  .   .     .   .   . . .    .   .  .  . .    .   . . .     .   . .    .     36
Part V         Reportable Transactions of a Reporting Corporation That Is a Foreign-Owned U.S. DE (see instructions)
               Describe on an attached separate sheet any other transaction as defined by Regulations section 1.482-1(i)(7), 
               such as amounts paid or received in connection with the formation, dissolution, acquisition, and disposition 
               of the entity, including contributions to and distributions from the entity, and check here.
Part VI        Nonmonetary and Less-Than-Full Consideration Transactions Between the Reporting Corporation 
               and the Foreign Related Party (see instructions)
               Describe these transactions on an attached separate sheet and check here.
                                                                                                                                 Form 5472 (Rev. 12-2023) 

Form 5472 (Rev. 12-2023)                                                                                                                              Page  3 
Part VII  Additional Information. All reporting corporations must complete Part VII. 
37    Does the reporting corporation import goods from a foreign related party?  .    .  . .    .    . . . .            . . . . .                 Yes No
38a   If “Yes,” is the basis or inventory cost of the goods valued at greater than the customs value of the imported goods?     .                 Yes No
b     If “Yes,” attach a statement explaining the reason or reasons for such difference. 
c     If the answers to questions 37 and 38a are “Yes,” were the documents used to support this treatment of the imported 
      goods in existence and available in the United States at the time of filing Form 5472?  . .    . . . .            . . . . .                 Yes No
39    During the tax year, was the foreign parent corporation a participant in any cost sharing arrangement (CSA)?  .       . . .                 Yes No
      If “Yes,” complete Part VIII as instructed below.
40 a  During  the  tax  year,  did  the  reporting  corporation  pay  or  accrue  any  interest  or  royalty  for  which  the  deduction  is  not 
      allowed under section 267A? See instructions .   . .  . .     . .  . .        . .  . .    .    . . . .            . . . . .                 Yes No
b     If “Yes,” enter the total amount of the disallowed deductions . .  . .        . .  . .    .    . . . .            . . . .  $
41 a  Is the reporting corporation claiming a foreign-derived intangible income (FDII) deduction (under section 250) with respect 
      to any transactions with the foreign related party?  If “Yes,” complete lines 41b, 41c, and 41d. See instructions     . . .                 Yes No
b     Enter the amount of gross receipts derived from all sales of general property to the foreign related party that the reporting 
      corporation included in its computation of foreign-derived deduction eligible income (FDDEI). See instructions .      . .  $
c     Enter  the  amount  of  gross  receipts  derived  from  all  sales  of  intangible  property  to  the  foreign  related  party  that  the 
      reporting corporation included in its computation of FDDEI. See instructions .  .  . .    .    . . . .            . . . .  $
d     Enter  the  amount  of  gross  receipts  derived  from  all  services  provided  to  the  foreign  related  party  that  the  reporting 
      corporation included in its computation of FDDEI. See instructions . .        . .  . .    .    . . . .            . . . .  $
42 a  Did the reporting corporation have any loan to or from the related party to which the safe-haven rate rules of Regulations 
      section 1.482-2(a)(2)(iii)(B) are applicable, and for which the reporting corporation used a rate of interest within the relevant 
      safe-haven range (100% to 130% of the applicable Federal rate (AFR) for the relevant term)?  .   . . .            . . . . .                 Yes No
b     Did the reporting corporation have any loan to or from the related party to which the safe-haven rate rules of Regulations 
      section  1.482-2(a)(2)(iii)(B)  are  applicable,  and  for  which  the  reporting  corporation  used  a  rate  of  interest  outside  the 
      relevant safe-haven range (100% to 130% of the AFR for the relevant term)?  .   .  . .    .    . . . .            . . . . .                 Yes No
43  a Did the reporting corporation issue a covered debt instrument in any of the transactions described in Regulations section 
      1.385-3(b)(2) during the tax year with respect to a related party that is a corporation, or, did the reporting corporation issue 
      or refinance indebtedness owed to a related party that is a corporation during the 36 months before or after the date of a 
      distribution or acquisition described in Regulations section 1.385-3(b)(3)(i) made by the reporting corporation, and either 
      the issuance or refinance of indebtedness, or the distribution or acquisition, occurred during the tax year?      . . . . .                 Yes No
b     If the answer to question 43a is “Yes,” provide the following.
      (1)  The amount of such transaction(s), distribution(s), and acquisition(s) . . .  . .    .    . . . .            . . . .  $
      (2)  The amount of such related party indebtedness  . . .     . .  . .        . .  . .    .    . . . .            . . . .  $
Part VIII Cost Sharing Arrangement (CSA)
Note: Complete a separate Part VIII for each CSA in which the reporting corporation was a participant during the tax year. Report all amounts in U.S. 
dollars. (See instructions.)
44    Provide a brief description of the CSA with respect to which this Part VIII is being completed.

45    During the course of the tax year, did the reporting corporation become a participant in the CSA?  . .            . . . . .                 Yes No
46    Was the CSA in effect before January 5, 2009?  .   .  . .     . .  . .        . .  . .    .    . . . .            . . . . .                 Yes No
47    What was the reporting corporation’s share of reasonably anticipated benefits for the CSA?  .    . . .            . . . . .                     %
48 a  Enter the total amount of stock-based compensation deductions claimed by the reporting corporation  .             . . . .  $
b     Enter the total amount of deductions for the tax year for stock-based compensation that was granted during the term of the CSA 
      and is directly identified with, or reasonably allocable to, the intangible development activity under the CSA  . . . . .     $
c     Was there any stock-based compensation granted during the term of the CSA to individuals who performed functions in 
      business activities that generate cost shared intangibles that was not treated as directly identified with, or reasonably 
      allocable to, the intangible development activity? .  . .     . .  . .        . .  . .    .    . . . .            . . . . .                 Yes No
49a   Enter the total amount of intangible development costs for the CSA . .        . .  . .    .    . . . .            . . . .  $
b     Enter the amount of intangible development costs allocable to the reporting corporation based on the reporting corporation’s 
      reasonably anticipated benefits share . . .      . .  . .     . .  . .        . .  . .    .    . . . .            . . . . $
Part IX   Base Erosion Payments and Base Erosion Tax Benefits Under Section 59A (see instructions)
50    Amounts defined as base erosion payments under section 59A(d) .    . .        . .  . .    .    . . . .            . . . .  $
51    Amount of base erosion tax benefits under section 59A(c)(2)   . .  . .        . .  . .    .    . . . .            . . . .  $
52    Amount of total qualified derivative payments as described in section 59A(h) made by the reporting corporation  .       .  $
53    Reserved for future use . . . .       . . .      . .  . .     . .  . .        . .  . .    .    . . . .            . . . .
                                                                                                                                Form 5472 (Rev. 12-2023)