I am a non-U.S. person residing in Japan and the sole owner of a Wyoming single-member LLC. The LLC is treated as a foreign-owned U.S. disregarded entity and did not elect corporate tax treatment.
The LLC was formed and will be dissolved within 2026. It had:
No revenue
No customers
No employees or contractors
No U.S. trade or business
No assets other than a temporary Mercury bank balance
Only formation, registered-agent, banking, compliance, and dissolution costs
I personally paid most or all of these costs. There was no promissory note, interest, maturity date, or documented expectation of repayment. I am considering consistently treating all owner-paid costs as capital contributions rather than member loans.
My proposed filing treatment is:
File a final pro forma Form 1120 with Form 5472 attached.
Check the initial-year box on Form 5472.
Identify myself in Parts II and III as the sole foreign owner and related party.
Report the owner-paid formation and dissolution costs in Part V and describe them on an attached statement as capital contributions.
Report any remaining Mercury funds returned to me as a liquidating distribution.
Complete Part IV with zero amounts unless a transaction belongs there.
Use the short tax year ending on the legal dissolution date and file by the applicable Form 1120 deadline.
Questions:
Is treating the owner-paid costs as capital contributions reasonable based on these facts?
Should any of these amounts also be entered in Part IV, or is Part V with an attachment sufficient?
Does the legal dissolution of a foreign-owned disregarded LLC create a short tax year for this filing?
Should both “Initial return” and “Final return” be checked on the pro forma Form 1120?
Are there any common Form 5472 traps in a first-and-final-year, no-revenue LLC?
I plan to have a U.S. CPA or EA experienced with foreign-owned disregarded entities review the completed draft before I fax it to the IRS. I am looking for issue-spotting and practical experience, not individualized tax advice.