Marking Foreign-Owned U.S. DE on a Pro Forma 1120 Packet

The practical answer

A packet's identifying annotation helps the preparer keep a special filing procedure visible throughout the document review. Check the exact wording and placement against the instructions instead of relying on an informal filename or an internal note that never appears on the form. Write "Foreign-owned U.S. DE" across the top of the pro forma Form 1120 to identify the special filing package described in the Form 5472 instructions.^{[1, p.2]}

Scope and the records behind the answer

The discussion follows the entity, form and transaction conditions identified below. The same label on a different form can have a different purpose. Keep the relevant entity and reporting period visible while you compare the requirements, and treat each stated exception as part of the rule rather than an optional footnote.

Official sources checked: 2026-11-09. Annual tax-year forms and continuously revised forms are identified separately in the references.

A side-by-side preparation table

Work through the official requirements

Proforma only fields

The special pro forma Form 1120 instructions for a foreign-owned U.S. DE require its name and address and items B and E on the first page. Do not automatically expand this into the full income-tax return for an ordinary C corporation.^{[1, p.2]}

Proforma top mark

Write "Foreign-owned U.S. DE" across the top of the pro forma Form 1120 to identify the special filing package described in the Form 5472 instructions.^{[1, p.2]}

De proforma required

A foreign-owned U.S. DE subject to Form 5472 filing attaches Form 5472 to a pro forma Form 1120 and files by the Form 1120 due date, including a valid extension.^{[1, p.2]}

Field/section Top annotation: Foreign-owned U.S. DE

Write "Foreign-owned U.S. DE" across the top of the pro forma Form 1120 to identify this special filing.^{[1, p.2]}

Field/section 1: Enter the form code for the return listed below that this application is for

Enter the code for the return being extended. A foreign-owned U.S. disregarded entity extending its Form 5472/pro forma 1120 package uses Form 1120 code 12 and the special DE notation at the top.^{[2, p.1] [1, p.2]}

Foreign owned de special route

A foreign-owned U.S. disregarded entity extending its Form 5472/pro forma 1120 package uses the Form 1120 code on line 1, writes Foreign-owned U.S. DE across the top and follows the special fax or mailing route in the Form 5472 instructions, rather than ordinary Form 7004 addresses.^{[1, p.3] [1, p.2] [2, p.1]}

This applies when: The filer is a foreign-owned U.S. disregarded entity. The extension concerns its Form 5472/pro forma 1120 package.

Proforma follow 5472 instructions

The IRS Appeals manual directs a foreign-owned U.S. DE to attach Form 5472 to a pro forma Form 1120 and submit it following the Form 5472 instructions.^[3]

This applies when: This states the information-filing procedure only. It is not a complete ordinary corporate Form 1120 income-tax guide and does not establish a signature waiver or requirement.

Proforma irm routing

The IRS corporate-return processing manual distinguishes a foreign-owned U.S. DE's pro forma Form 1120 from ordinary Form 1120 income-tax data processing. The DE attaches Form 5472 as required, while the manual says not to process that pro forma as an ordinary Form 1120.^[4]

This applies when: This is internal IRS processing guidance, not cancellation of the pro forma Form 1120/Form 5472 submission obligation or an express signature waiver. Only the January 1, 2026 paragraph in IRM 3.11.16.11(2) is relied on; other paragraphs on the page dated 2027 are not treated as already effective.

Field/section Attachment: Form 5472 attached

Attach Form 5472 for every reportable related party, with the applicable schedules, to the pro forma Form 1120 and submit through the special DE route.^{[1, p.2]}

An illustrative preparation scenario

In this hypothetical preparation example, an owner's folder is named foreign-owned LLC, but the draft cover form has no corresponding annotation. The preparer compares the form itself with the special instructions and reviews the complete assembled copy rather than assuming that the folder name identifies the package to its recipient. The preparer checks three points: What exact annotation is prescribed? Does it appear on the form itself? Does the assembled copy preserve it clearly? The file remains a working comparison until the relevant facts and applicable instructions have been checked together. No agency outcome is assumed.^{[1, p.2]}

This is a planning illustration, not a statement that a particular filing has been accepted or that an entity qualifies for a tax result. Use the source-backed distinctions above to decide what information still needs to be established before a form is completed.

A review sequence you can actually use

1. What exact annotation is prescribed?
2. Does it appear on the form itself?
3. Does the assembled copy preserve it clearly?

Write down the answer and the record that supports it, rather than marking a question complete because a field contains text. When two records disagree, identify whether the difference concerns the entity, an individual, the reporting period or the type of change. That makes the remaining question specific enough to resolve against the relevant instruction.

Keep the scope of a preparation service separate from the government requirement. A service intake question may gather information for a workflow; it does not create an exception, extend a deadline or determine whether a transaction is reportable. The cited government material remains the basis for those conclusions.

Questions to settle before moving forward

How should I check de proforma required?

A foreign-owned U.S. DE subject to Form 5472 filing attaches Form 5472 to a pro forma Form 1120 and files by the Form 1120 due date, including a valid extension. ^{[1, p.2]}

How should I check field/section top annotation: foreign-owned u.s. de?

Write "Foreign-owned U.S. DE" across the top of the pro forma Form 1120 to identify this special filing. ^{[1, p.2]}

How should I check field/section 1: enter the form code for the return listed below that this application is for?

Enter the code for the return being extended. A foreign-owned U.S. disregarded entity extending its Form 5472/pro forma 1120 package uses Form 1120 code 12 and the special DE notation at the top. ^{[2, p.1] [1, p.2]}

How should I check foreign owned de special route?

A foreign-owned U.S. disregarded entity extending its Form 5472/pro forma 1120 package uses the Form 1120 code on line 1, writes Foreign-owned U.S. DE across the top and follows the special fax or mailing route in the Form 5472 instructions, rather than ordinary Form 7004 addresses. The filer is a foreign-owned U.S. disregarded entity. The extension concerns its Form 5472/pro forma 1120 package.^{[1, p.3] [1, p.2] [2, p.1]}

Official sources and versions

1. Instructions for Form 5472 (Rev. December 2024) — Rev. December 2024
2. Form 7004 (Rev. December 2025) — Rev. December 2025
3. Part 8. Appeals
4. Part 3. Submission Processing

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