Canadian Owner of a US LLC: Form 5472 in the US, T1134 in Canada
Summary
The US and Canada classify the same LLC in opposite ways. The LLC files Form 5472 with the IRS by April 15; you usually report it to the CRA as a foreign affiliate on Form T1134, not T1135.
The same LLC is two different things on either side of the border, and each side's paperwork follows its own view.
| United States | Canada | |
|---|---|---|
| How the LLC is classified | Disregarded for income tax, but a corporation for Form 5472 | A foreign corporation |
| What gets filed | Form 5472 with a pro forma Form 1120, by the LLC | Usually Form T1134, by you, because the LLC is your foreign affiliate |
| When | April 15, or October 15 with Form 7004 | T1134 within 10 months after your tax year ends |
Both countries run a January to December tax year, so at least the calendar is shared.
The US side
A single-member LLC with a Canadian owner is treated as a corporation for this reporting under Treas. Reg. §301.7701-2(c)(2)(vi), and IRC §6038A requires it to file Form 5472 each year it has a reportable transaction with you: money you put in, money it pays you, costs you pay for it, loans either way. The form is attached to a pro forma Form 1120 that computes no tax, and sent by mail or fax to the IRS in Ogden, Utah.
The US-Canada treaty does not change this. Form 5472 is an information return, and treaties do not remove those.
The Canadian side: T1134, not T1135
Canada does not follow the US election. The CRA treats a US LLC as a corporation. If you own 10% or more of it, and a single-member LLC means you own all of it, it is your foreign affiliate, and a Canadian resident with a foreign affiliate generally files Form T1134 each year.
T1135, the foreign property statement many Canadians already know, covers foreign property such as foreign bank accounts and shares of foreign corporations, but not shares of a foreign affiliate. Filing T1135 for the LLC instead of T1134 is a common and expensive mix-up.
How the LLC's income is taxed in Canada, and how the treaty applies to income earned through an LLC, is one of the harder corners of cross-border tax. It is a question for a Canadian adviser who works with US entities, and this page does not attempt it.
A Toronto example
Liam runs a small analytics consultancy in Toronto through a Delaware LLC formed in 2024.
- 2025: he put in $8,000 in February to cover a contractor; the LLC's US clients paid it $95,000; it paid Liam $60,000 over the year.
- US: the 2025 Form 5472, due April 15, 2026, reports the $8,000 contribution and the $60,000 paid to him. Client payments are not on it.
- Canada: Liam files his own return, and a T1134 for the LLC as his foreign affiliate for 2025, within the 10-month window after December 31, 2025. His adviser decides how the LLC's income and the $60,000 are reported.
The advice Canadian owners are most often given
Canadian owners are often told by a Canadian accountant that the LLC "has no US filing because it is disregarded". For income tax that can be true. For Form 5472 it is not. If years were missed, file them together with a statement explaining the delay; the penalty for a missing return is $25,000 per form under IRC §6038A(d)(1), and the missed Form 5472 page sets out the route.
For a single-owner LLC with ordinary transactions, FileTax prepares the Form 5472 and pro forma Form 1120 packet in under 15 minutes for $99 per year. The filing requirements page lists everything a foreign-owned LLC owes in the US.
Questions Canadian owners ask
My accountant said my LLC is disregarded, so nothing is filed in the US. Is that right?
Not for Form 5472. A foreign-owned single-member LLC is treated as a corporation for that reporting and files it each year with a pro forma Form 1120.
Do I file T1135 or T1134 for my US LLC?
Generally T1134. Canada treats the LLC as a corporation, a single-member LLC is your foreign affiliate, and T1135 does not cover shares of a foreign affiliate. Confirm with your Canadian adviser.
Does the US-Canada treaty remove the Form 5472 filing?
No. It deals with income tax. Form 5472 is required regardless.
Is the IRS deadline the same as the CRA deadline?
No. The LLC's Form 5472 is due April 15. Your own Canadian return and the T1134 follow the CRA's dates.
Related pages
Continue reading
Form 5472: The Complete Guide for Foreign-Owned US LLCs →
A foreign-owned US single-member LLC files Form 5472 with a pro forma Form 1120 by April 15. Funding the LLC is itself reportable. Missing it costs $25,000 per form, per year.
US Tax Filing Requirements for Foreign-Owned LLCs →
A foreign-owned US LLC files Form 5472 with a pro forma 1120 by April 15, plus its state annual report. BOI reporting no longer applies. US income tax is usually zero.
US LLC Tax Obligations for UK Residents - Form 5472 and US-UK Treaty Considerations →
UK founders of US LLCs sometimes assume the US-UK treaty handles their US obligations. The treaty does not address information returns. Form 5472 is required.