What is the accuracy-related penalty under IRC 6662 and when does it apply?
The IRS audited my foreign-owned LLC and says I understated my income. They are assessing a 20% accuracy-related penalty on top of the additional tax. What triggers this penalty and is there any way to avoid it? Can having a professional prepare my return protect me?
Related Questions
What is the accuracy-related penalty under IRC 6662 and when does the IRS impose it on foreign LLC owners?
I just received a letter from the IRS saying they're proposing a 20% accuracy-related penalty on an adjustment they made to my LLC's tax return. They said I understated my income by not properly repor...
Can First-Time Abatement remove the accuracy penalty on my CP2000?
My CP2000 added a 20% accuracy penalty on top of the extra tax. I've never had a penalty before, so can I just ask for First-Time Abatement to get it removed? If not, what's the right way to fight the...
What are the transfer pricing penalties for foreign-owned LLCs?
My U.S. LLC receives management services from my company overseas and pays fees for those services. The IRS is questioning whether the prices are at arm's length. What transfer pricing penalties could...
What is the trust fund recovery penalty and can it apply to foreign LLC owners?
My foreign-owned U.S. LLC has employees and I handle payroll. I fell behind on payroll tax deposits. Someone told me the IRS can hold me personally liable for the unpaid payroll taxes through somethin...
What are the penalties under IRC 6651 for filing late or paying late, and how do they apply to foreign LLC owners?
I'm a Nigerian business owner with a Wyoming LLC. I missed the April 15 deadline for filing my Form 5472 and pro forma 1120 last year. I also have some ECI that I owe tax on, and that payment is late ...
My CPA mentioned IRC 7701(a)(30) — what does 'U.S. person' mean for my foreign-owned LLC?
I live in Germany and own a single-member LLC in Wyoming. My CPA keeps referencing IRC Section 7701(a)(30) when explaining why I file differently than a domestic owner. He says I'm not a 'U.S. person'...
Does a missing Form 5472 keep my whole LLC year open under section 6501(c)(8)?
I filed my pro forma Form 1120 for my foreign-owned single-member LLC on time, but I completely forgot to attach Form 5472 for a couple of years. Someone told me the normal three-year audit window doe...
If I should have filed Form 8938 but didn't, does that keep my tax year open too?
My LLC may have crossed into being a specified domestic entity, and I think I should have filed Form 8938 with the return but didn't. Separate from the $10,000 penalty, does leaving Form 8938 off the ...
My CPA mentioned IRC 267 and said I can't deduct certain expenses paid to my own foreign company — why?
I'm a Brazilian citizen and I own both a consulting firm in Brazil and a Delaware LLC. My Brazilian company provides back-office services to the LLC and charges a monthly fee. My CPA said IRC 267 rest...
Can the IRS get my passport revoked if my Wyoming LLC owes back tax?
I'm a Mexican citizen with a Wyoming LLC. The LLC has unpaid Form 5472 penalties from 2023 and 2024 totaling around $50,000. I just renewed my Mexican passport and I'm planning to visit the U.S. for a...
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