EA needed: Form 5472 + 1065 for foreign-owned WY LLC

I need an Enrolled Agent (or CPA) experienced with foreign-owned US entities. This is a niche fact pattern — please only apply if you have actually filed these forms before. SITUATION - Wyoming LLC, currently a foreign-owned single-member disregarded entity - I have been filing Form 5472 + pro forma 1120 annually - Adding a second member in 2026, so the LLC converts to a partnership mid-year - Both members are non-resident aliens (Romanian citizens living in the Philippines) - No US trade or business, no ECI, no US-source income, no US employees or contractors, no inventory in the US - Bank account with Relay; low transaction volume SCOPE 1. Short-period Form 5472 + pro forma Form 1120 covering the disregarded-entity portion of 2026 2. Short-period Form 1065 for the partnership portion of 2026, including Schedule K-1 for each partner and Schedules K-2/K-3 3. Brief written guidance on the conversion date and opening capital accounts Please quote items 1 and 2 separately. QUESTIONS — please answer in your proposal 1. How is Form 5472 transmitted to the IRS? 2. Does the domestic filing exception to Schedules K-2/K-3 apply to a partnership with two direct foreign partners? 3. When a foreign-owned disregarded entity converts to a partnership mid-year, when is the final short-period 5472 due? 4. Do foreign partners need ITINs for their K-1s when the partnership has no ECI? REQUIREMENTS - Active PTIN; you sign as paid preparer (I will not file anything as self-prepared) - Fixed-price milestones, all work and payment through Upwork - Available for the following tax year as well Please state your EA or CPA number so I can verify it.