Distribution types
- Operating distributions: regular periodic distributions of profit
- Special distributions: one-time distributions for specific events
- Liquidating distributions: final distributions on LLC dissolution
- Return of capital: refund of capital contributions (not income)
How to make distributions
- Confirm operating agreement allows distribution (some require unanimous member vote)
- Calculate distribution amount per ownership or waterfall
- Wire from LLC bank account to member
- Document in bookkeeping (debit member capital, credit cash)
- Report on Form 5472 Part IV (foreign-owned single-member) or K-1 (multi-member)
Tax treatment for non-residents
- Single-member foreign-owned LLC: distribution is reported on Form 5472 but is not a separate income event
- Multi-member LLC: K-1 shows partner's share of partnership income (taxable to partner regardless of distribution)
- NOT subject to 30% US withholding (distributions are not US-source FDAP)
- Subject to home country tax under worldwide income rules