IRS Compliance & PenaltiesAnswered

I got a Form 5472 penalty notice and now I keep hearing about a 90-day clock. What should I actually be doing before that turns into more penalties?

BE
bassam_eb62subscriber
October 11, 2025 2,146 views 1 answer
form-5472penalty-noticecontinuation-penaltycomplianceforeign-owned-llcnotice-response

The notice itself was stressful enough, but then someone mentioned that if the failure continues for more than 90 days after IRS notification there can be more penalties layered on top. That turned what I thought was one notice problem into a timeline problem. I do not want to spend the next two months debating strategy while the underlying issue remains open.

What I need is the operational answer. If the real priority is closing the filing or records gap before the continuation structure kicks in, I want to organize the response around that rather than writing a long explanation letter that leaves the core failure unresolved.

Related Questions

ComplianceAnswered

We fixed the Form 5472 problem after the notice but before the 90-day point. What proof matters most if the IRS still pushes continuation penalties?

Once we realized the notice could turn into an additional penalty timeline, we stopped debating and repaired the underlying problem as fast as we could. The corrected package was sent, the records wer...

IB
ibrahim_b95f·Oct 20, 2025
1,5881
ComplianceAnswered

People keep telling me to ask for first-time abatement. Should I do that before arguing reasonable cause?

I am in Singapore and my Delaware LLC received a filing penalty related to our first year of U.S. compliance. Various people online say to ask for first-time abatement first because it is easier than ...

BS
benjamin_sg_fe0f·Jan 16, 2025
2,1901
ComplianceAnswered

How do the $25,000 + $25,000-per-30-day section 6038A penalties for failing to keep records actually work?

I understand the famous $25,000 Form 5472 penalty, but I'm fuzzy on how it stacks when the problem is recordkeeping rather than a missed form, and how the extra per-period penalty kicks in. Is failing...

OA
Olufemi A.·May 19, 2026
1,7201
ComplianceAnswered

Should I dispute the penalty by letter now, or pay first and use Form 843 later?

I keep seeing two different tracks described online. One is to write back to the notice and ask the IRS to reconsider the penalty. The other is to pay and then file Form 843 for a refund or abatement....

E7
emre_7f8f·Oct 12, 2025
1,9641
ComplianceAnsweredFeatured

I just got a $25,000 Form 5472 penalty notice. What should I do first?

I am in India and own a Delaware single-member LLC. We filed late and now received an IRS notice assessing a $25,000 Form 5472 penalty. Revenue was only about $18,000, so the penalty is larger than th...

VI
vikram_in_7c07·Jan 12, 2025
3,6501
ComplianceAnswered

My Form 5472 penalty notice went to an old registered-agent address. How should I frame the response?

I only learned about the penalty because my former registered agent finally forwarded a notice packet months after the IRS had mailed it. The LLC had already changed mailing arrangements, but the old ...

VC
valeria_c1f5·Aug 21, 2025
1,7041
ComplianceAnswered

My foreign company was already registered in a U.S. state before the 2025 BOI rule changed. If we missed the one-time deadline, where do we even start?

I live in Israel and our main company is formed outside the U.S., but it has been registered to do business in one U.S. state for some time. We were so focused on the headlines about domestic companie...

N2
noam_2e42·Jul 5, 2025
1,8901
ComplianceAnswered

The IRS denied my penalty relief request. Is Appeals actually the next step, or do I need a completely different type of filing now?

The denial letter is what rattled me because it felt final at first glance. But after reading more carefully, I realized the denial of relief might simply be the point where an appeal becomes availabl...

ND
noor_d481·Oct 13, 2025
1,8361
ComplianceAnswered

I got an IRS penalty notice on my LLC — is it a CP15 or a CP215, and how do I respond?

My foreign-owned LLC just got an IRS notice assessing a penalty tied to Form 5472. A forum post called it a CP15, but my notice header looks different. Does the notice type actually matter, and what i...

TB
thiago_b9d2·May 19, 2026
1,1101
ComplianceAnswered

At what point does a Form 5472 penalty case become serious enough for Form 911 and the Taxpayer Advocate Service?

I do not want to over-escalate too early, but I also do not want to be stubborn about staying in ordinary channels once the case is clearly causing real damage. The company has already sent documents,...

HE
hussein_ef80·Oct 14, 2025
1,7401

Have a similar question?

ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.

Become a Member — $9.99/mo

Disclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.

Watch the walkthroughs