Perhaps in response to the increased discussions that U.S. is becoming a potential tax haven and the continued pursuit of transparency by the government, the Treasury announced on March 30 that it will be issuing proposed regulations to expand on Section 6038A. Certain states allow formation of limited liability companies without disclosure of the ownership structure, which is where the view that the U.S. can be a tax haven for foreign investors originates. Section 6038A requires certain foreign-owned U.S. corporations to file Form 5472 (Information Return of a 25-percent Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in U.S. Trade or Business). Form 5472 requires disclosure of the direct and indirect foreign beneficial ownership of a U.S. corporation as well as a list of intercompany transactions which the U.S. corporation may have with that particular foreign-related party (e.g., intercompany financing, purchase or selling of goods or services).