Types of capital contributions
- Cash: wire, check, or transfer from member's personal account to LLC bank account
- Property: business equipment, inventory, intellectual property
- Services: rare for non-resident LLCs; complicated for tax (services for equity is taxable income to member)
- Promissory note: member promises future payment; tracked as receivable
Form 5472 reporting
- Capital contributions from foreign owner appear on Form 5472 Part V (amounts paid TO the LLC by related parties)
- Reportable amount: cash value of contribution
- Property contributions reported at fair market value
- Tracked annually on each year's Form 5472
Tax treatment
- Cash contributions: not taxable income to LLC (no revenue)
- Property contributions: no taxable event at LLC level; member may recognize gain if appreciated property is contributed
- Capital account adjusts upward for member by contribution amount
- For multi-member LLCs, special allocations require substantial economic effect under IRC Section 704(b)