Can I use an Offer in Compromise to settle foreign LLC penalties?
My foreign-owned LLC has accumulated over $100,000 in Form 5472 penalties across multiple years. I cannot afford to pay the full amount. Can I submit an Offer in Compromise (OIC) to settle for less? What are the chances of success for international penalties?
Related Questions
Can I use the streamlined procedures to fix the LLC's missed Form 5472 itself?
I am in the UK and my bigger headache is a missed Form 5472 for an older year. Someone in a founder group told me to just use the IRS streamlined procedures because they worked for missed foreign fili...
What are the Delinquent International Information Return Submission Procedures?
I missed filing Form 5472 for my foreign-owned LLC but I do not have any unreported income or unpaid tax. My accountant says I might be able to file the late forms without penalty using the Delinquent...
Does First Time Abatement apply to Form 5472 or other international penalties?
I heard the IRS has a First Time Abatement policy that removes penalties for first-time offenders. Does this apply to international information return penalties like Form 5472 or Form 5471? I have a c...
Can I set up an installment agreement to pay IRS penalties over time?
I owe $75,000 in Form 5472 penalties and I cannot pay the full amount at once. Does the IRS offer installment agreements for penalty-only balances? What are the terms and how do I apply? Will interest...
Can I use reasonable cause to get Form 5472 penalties removed?
I received a $25,000 penalty notice for not filing Form 5472 for my foreign-owned LLC. My tax preparer in my home country never told me about this form. Can I argue reasonable cause to get the penalty...
What is the statute of limitations for IRS penalties on foreign information returns?
My foreign-owned LLC did not file Form 5472 for 2019, 2020, and 2021. Is there a statute of limitations that might protect me from penalties on the older years? I heard that the statute of limitations...
If I missed Form 5472 two years ago, is the problem only the penalty or is the year still open too?
I am in Australia and my Delaware LLC missed a Form 5472 filing for an earlier year because I did not understand owner-paid expenses counted as reportable transactions. I was mentally treating the iss...
What is the $25,000 penalty for failing to file Form 5472?
I own a single-member LLC as a foreign person and just learned about Form 5472. I never filed it since forming my LLC two years ago. What exactly is the penalty for not filing, and can it really be $2...
How do I write a penalty abatement request letter to the IRS?
I need to write a letter to the IRS requesting abatement of Form 5472 penalties for my foreign-owned LLC. What should the letter include? Is there a specific format the IRS expects? I want to make sur...
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....
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