Tax law never stands still — and if you're a business with foreign ownership, you know that changes in Washington can ripple straight into your reporting obligations. With President Trump's One Big Beautiful Bill Act (OBBBA) signed into law in July 2025, we've entered another era of reform.
So, what's new — and more importantly, what does it mean if you're filing Form 5472 this year? Let's break it down.
What Changed Under Trump's New Bill?
The OBBBA builds on and extends the 2017 Tax Cuts and Jobs Act. Here are the big highlights:
- Tax rates stay put: Individual brackets (10%–37%) are locked in permanently, inflation-adjusted.
- Business perks extended: The higher standard deduction and the 20% qualified business income (QBI) deduction live on.
- SALT cap raised (temporarily): Joint filers can deduct up to $40,000 through 2029, before it snaps back to $10,000.
- Estate and gift tax exemption: Bumped permanently to $15M per person, indexed to inflation.
International Rules Reshaped:
- GILTI becomes Net CFC Tested Income (NCTI) at a 12.6% effective rate
- FDII morphs into Foreign-Derived Deduction Eligible Income (FDDEI) at 14%
- BEAT tax fixed at 10.5%
In short: lower taxes for many, new names and rates for international income, and plenty of changes to digest.
Quick Refresher: What Is Form 5472?
Form 5472 is the IRS's way of keeping tabs on foreign-owned U.S. corporations and foreign corporations doing business in the U.S.
You'll need to file if you're:
- A U.S. company with 25% or more foreign ownership
- A foreign company with U.S. business activities
- A U.S. disregarded entity owned by a foreign person
It reports transactions with related foreign parties, from loans to sales to service fees. And the penalties for missing or messing it up are steep — $25,000 per failure, with additional fines piling on if you delay.
What's New for Form 5472 Filers?
The form itself was last revised in December 2024, and while the Trump bill didn't change the form directly, here are the key updates to keep in mind:
- More detail in Part VII: Especially for safe-haven interest and covered debt instruments.
- Electronic filing only: Attach to Form 1120 or a pro forma return if you're a disregarded entity.
- Hefty penalties: $25,000 fines per incomplete or late filing still apply, with extra charges every 30 days until you comply.
So while the paperwork hasn't changed much, the context in which you're reporting has.
Where Trump's Changes Collide With Form 5472
Here's how the new tax law could affect your filings, even without altering the form itself:
| Area | What It Means |
|---|---|
| Reporting burden stays heavy | You'll still need to disclose all related-party transactions — no shortcuts here. |
| International income rules shift | The renaming of GILTI and FDII into NCTI and FDDEI changes how much tax applies to foreign-sourced income. |
| Debt and interest transactions | With safe-haven interest and covered debt rules spelled out more clearly, expect closer IRS scrutiny. |
| Penalties unchanged | The IRS is unlikely to go easier during a reform period — if anything, expect tougher audits. |
Takeaways for Businesses
| Area | What It Means |
|---|---|
| Form design | Same as 2024 revision |
| Tax law impact | International tax changes may alter reported amounts |
| Filing process | Electronic only, penalties unchanged |
| Action point | Get ahead on documentation & work with advisors |
Need Help With Your Form 5472?
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Start Your Filing NowFinal Thoughts
Form 5472 might not have changed on paper, but the tax environment around it has. Trump's OBBBA reshapes how foreign-owned U.S. companies are taxed, especially when it comes to international income and related-party dealings.
The bottom line? Stay compliant, stay accurate, and don't cut corners. A late or incomplete Form 5472 could cost you tens of thousands, and in this new landscape, it's smarter than ever to get professional advice.
Key Actions for 2025:
- Review the implications of GILTI/NCTI and FDII/FDDEI regime changes on your tax positions
- Update internal processes to ensure safe-haven interest and covered debt disclosures are accurate
- Maintain compliance rigorously — file electronically on time with complete reporting
