Annual Compliance Planner

Free guide · Compliance

For foreign-owned US businesses | 2026 close and 2027 planning

By Mukund Srinivas | Business Head, NYBACS · Updated · Version 1.2

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Build the calendar around the entity

Start with federal tax classification, year-end, ownership and state footprint. An LLC label alone does not identify the return. This planner assumes a 31 December 2026 year-end for the dated examples; fiscal years, short periods and special rules require a separate calendar.

Entity / tax statusInitial filing review
US C corporationForm 1120; assess Form 5472 for qualifying foreign ownership and related-party transactions. [1, 3]
Multi-member LLC taxed as partnershipForm 1065 and partner reporting; separately assess foreign-partner withholding and owner-level returns. [2]
Foreign-owned disregarded US entityAssess Form 5472 with pro forma Form 1120 when reportable transactions occur; owner-level obligations may also apply. [3]

Create the entity control record

  • Legal name, EIN, formation state and formation date recorded.
  • Tax classification and any elections confirmed with the preparer.
  • Owners, ownership changes and related parties documented.
  • All states with people, property, inventory or sales identified.
  • Prior filings, notices, extensions and payment confirmations collected.

Entity __________ year-end __________ preparer __________ internal owner __________

Core planning dates for 2027

These dates apply standard current rules to the 2026 calendar year. Confirm final filing-year instructions, relief and entity-specific exceptions before relying on them. An extension to file generally does not extend the time to pay. [1, 2, 4]

Planning datePotential obligationWho should review
1 February 20272026 Forms W-2 / 1099-NEC, where required. January 31 falls on Sunday. [5]Employers and businesses with reportable payments
1 March 2027Delaware domestic corporation annual report and franchise tax for 2026. [6]Delaware corporations
15 March 2027Calendar-year Form 1065 or timely extension request. [2, 4]Partnership-taxed entities
15 April 2027Calendar-year Form 1120 or timely extension; assess related Form 5472 package. [1, 3, 4]C corporations and applicable foreign-owned disregarded entities
1 June 2027Delaware LLC annual tax for 2026; no LLC annual report. [9]Delaware LLCs
15 September 2027Extended calendar-year Form 1065, if extension valid. [2, 4]Partnership-taxed entities
15 October 2027Extended calendar-year Form 1120 and applicable associated reporting, if extension valid. [1, 3, 4]Applicable corporate / disregarded-entity filers

Internal recommendation: assign preparation deadlines 30 days before the statutory deadline and an approval checkpoint 10 days before it. These are workflow targets, not statutory dates.

Recurring controls that prevent missed filings

Frequency / triggerAction and evidence
MonthlyReconcile bank, cards and payment processors; post parent transactions; retain statements and invoices; review notices.
Before payroll / each payrollConfirm registrations, payroll settings and funding; reconcile submissions, tax debits and any reversals. Filing deadlines and deposit deadlines differ. [5]
QuarterlyReview state footprint, taxable sales, estimated taxes and payroll obligations with the advisers responsible.
Ownership or operating changeReassess tax classification, reporting, registrations and bank KYC. Changes include acquisitions, new states and new owners.
Year-endClose ledgers; reconcile intercompany balances; collect payee documentation; confirm return scope and extensions.

Worked example: no revenue does not mean no review

Scenario. A foreign individual owns a US single-member LLC with no corporate election. During 2026 the owner contributes $12,000, the LLC pays $2,000 in costs and receives no customer revenue. Closing cash is $10,000, assuming no other transactions.

The contribution is a reportable-transaction consideration for Form 5472 even though sales are zero. On these assumptions, prepare the Form 5472/pro forma Form 1120 filing review and the state obligations separately. A failure to file Form 5472 can trigger a $25,000 penalty. [3]

Evidence register

ObligationOwner / due dateProof saved
Federal return / extension________________________________
State return / annual report________________________________
Tax payment confirmation________________________________
Notice response / follow-up________________________________

Completion means accepted filing evidence and payment confirmation where relevant, not merely that documents were sent to a preparer.

Authoritative sources

[1] IRS - Form 1120 instructions
https://www.irs.gov/instructions/i1120

[2] IRS - Form 1065 instructions
https://www.irs.gov/instructions/i1065

[3] IRS - Form 5472 instructions
https://www.irs.gov/instructions/i5472

[4] IRS - Form 7004 instructions
https://www.irs.gov/instructions/i7004

[5] IRS - Employment tax due dates
https://www.irs.gov/businesses/small-businesses-self-employed/employment-tax-due-dates

[6] Delaware - Corporate annual reports and tax
https://corp.delaware.gov/paytaxes/

[7] FinCEN - Current BOI reporting guidance
https://www.fincen.gov/boi

[8] FinCEN - Customer due diligence rule
https://www.fincen.gov/resources/statutes-and-regulations/cdd-final-rule

[9] Delaware - LLC/LP/GP annual tax
https://corp.delaware.gov/alt-entitytaxinstructions/

Sources accessed 25 October 2026. Dates are planning applications of current rules, not a representation that all final 2027 instructions have been issued. Review again before the 2027 filing season.

By Mukund Srinivas, Business Head, NYBACS. General educational guidance; not a complete filing determination or a substitute for entity-specific tax advice.

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