Corporation with foreign shareholder

I have a tax case inquiry about a foreign person plans to establish a corporation in the US.

I have not handled a case like this before so I had to do a little research. My initial understanding is that Form 5472 is required if the corporation is 25% or more under foreign ownership.

Are there other potential complications in addition to the Form 5472 requirement?

If/when the US corporation pays dividends, interest, or royalties to the foreign person, a 30% withholding tax can apply. Section 1441. If in a treaty country, the treaty may reduce the withholding rate. Getting into treaties and withholding can get complicated. In addition, if the shares of the US company are sold, you need to consider FIRPTA withholding. Section 1445.