A $25,000 Form 5472 penalty notice is often removable.
If a missed Form 5472 triggered a $25,000 notice, you have a path — but the clock is running. A reasonable-cause abatement request can remove the penalty, and bringing your unfiled years current is usually straightforward. The most important thing is to act before your notice deadline.
Every foreign-owned single-member US LLC has to file Form 5472 — even with zero activity.
Form 5472 is filed each year together with a pro-forma Form 1120, and it applies even if the company earned nothing, spent nothing, and holds no money. Most owners never hear about it until a notice arrives.
The penalty is $25,000 per form. If it stays unfiled after the IRS's 90-day notice, another $25,000 accrues for each 30-day period that follows. There is no statute of limitations until the return is filed, and Form 5472 cannot be e-filed — it goes in by mail or fax only. (As of 2026.)
It's a large number on an official letter, which is exactly why it causes panic. But a first, honest failure to file is one of the situations the IRS's reasonable-cause relief is built for — and the penalty is often removable when the case is made properly and the missing filings are brought current.
From notice to resolved, handled for you
One team takes the letter off your desk and carries it through to a response filed with the IRS.
Assess your notice & history
We read the exact notice you received, identify which years and forms are involved, and map your full filing history so nothing is missed.
Prepare the abatement request
We build the written reasonable-cause request the IRS looks for, documenting why the forms were missed and why ordinary business care applies.
Bring unfiled years current
We prepare each missing Form 5472 and its pro-forma Form 1120 and get the delinquent years filed correctly — by mail or fax, as the form requires.
Respond to the IRS for you
We correspond with the IRS directly, track the response, and handle the follow-ups until the matter is resolved.
What strengthens a reasonable-cause request
The IRS weighs the specifics of each case. A few circumstances commonly support a reasonable-cause request — and non-resident owners often have several of them.
A first-time slip
A clean prior record — no history of the same missed filing — is a factor the IRS considers when it looks at reasonable cause.
Prompt correction
Acting quickly once you learn of the problem, and filing the delinquent forms without delay, demonstrates good faith.
Genuine confusion abroad
Not being told that a zero-activity foreign-owned LLC owes an annual federal filing is an understandable, common situation for owners outside the US.
Reliance on a service
Many owners formed through a service that filed the company but never mentioned Form 5472. Reasonable reliance on a provider is part of the picture.
Respond within the window on your notice
The additional $25,000-per-30-day charge begins after the IRS's 90-day notice period, so the single most important step is to respond within the deadline printed on your letter. The sooner a complete, documented response is on its way, the better your position. If your deadline is close, reach out today.
The questions owners ask when a notice arrives
Clear answers, in plain language, to what brings people to this page.
Can the penalty really be removed?
Often, yes. The IRS provides reasonable-cause relief for taxpayers who failed to file despite exercising ordinary business care, and a missed Form 5472 by a non-resident owner is a common reasonable-cause situation. It is not automatic — the case has to be made in writing and the filings brought current — but the path exists.
I have several unfiled years — is that a problem?
It's common and workable. Each year is its own Form 5472 with a pro-forma Form 1120. We prepare all the missing years together and address them as one coordinated response rather than piecemeal.
Do I owe tax too, or just the form?
Form 5472 is an information return, not a tax bill — the $25,000 is a penalty for not filing it, not tax on income. Whether you owe any actual US income tax is a separate question that turns on whether you're engaged in a trade or business in the United States (ETBUS) and on any treaty between the US and your country. We look at both.
How long does abatement take?
It depends on the IRS's processing times and the specifics of your case, which we don't control. What we do control is a complete, well-documented request filed promptly, and we track it with the IRS until there's a resolution.
What if I ignore it?
The penalty doesn't go away on its own. After the IRS's 90-day notice, another $25,000 can accrue for each 30-day period that follows, there is no statute of limitations until you file, and continued non-response can move the matter toward collection. Acting — even late — is almost always better than waiting.
Can you help if I haven't received a notice yet but know I missed it?
Yes. If you know Form 5472 went unfiled, filing before the IRS contacts you is the strongest position. We bring the years current, and where a penalty has already been assessed, prepare the reasonable-cause abatement request.
Let's get your Form 5472 notice handled.
Send us the notice and your company basics — we'll assess it, bring your filings current, and respond to the IRS.