SDOP vs SFOP — how do I know which Streamlined track applies to me?
I keep seeing 'SDOP' and 'SFOP' for the Streamlined Procedures and I can't tell which one I fall under. I'm a foreign citizen who spends part of the year in the US. Does it come down to where I live, and does the difference actually change what I pay?
Related Questions
I missed FBARs for several years — do I use the Delinquent FBAR procedures or Streamlined?
I just realized I should have been filing FBARs for my foreign accounts and I'm a few years behind. I keep seeing two different fixes: the 'Delinquent FBAR Submission Procedures' and the 'Streamlined'...
How is the 5% Streamlined (SDOP) penalty actually calculated?
I think I fall under SDOP. People keep saying '5% penalty' but 5% of what, exactly? Is it 5% of every year's balance added together, or 5% of the highest balance I ever had? I want to estimate the cos...
Our late Form 8832 seems outside the easy relief window. How do we know when it turns into a private-letter-ruling case?
We intended corporate treatment from formation, but the election was not actually filed, and now enough time has passed that I am no longer sure the standard relief procedure is available. One adviser...
My company is formed in the UK and registered in New York. Does that still make me a BOI filer even though domestic LLCs are exempt now?
I am a UK resident and my business is a UK company that registered to do business in New York instead of forming a new U.S. LLC. After the 2025 BOI rule changes, I got confused because everyone now ta...
Real-estate-heavy partnership LLC: buyer's counsel says FIRPTA and 1446(f) both apply — do we stack 15% plus 10%?
I'm a foreign member selling my interest in a US LLC taxed as a partnership. Most of its value is a commercial building. The buyer's lawyer flagged that a FIRPTA rule for partnership interests AND the...
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...
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 ...
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?
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 wh...
Form 8275 or Form 8275-R — which one do I file to disclose a tax position on my foreign-owned LLC return?
My CPA wants to take a position on my U.S. LLC's pro forma 1120 that he says goes against a Treasury regulation. He mentioned filing either Form 8275 or Form 8275-R but I don't really understand which...
I missed Form 5472 last year — how do I avoid the $25,000 penalty?
I formed my foreign-owned US LLC in 2024 but never filed Form 5472 for the 2024 tax year. I just learned this exists and I'm panicking about the $25,000 penalty. I haven't received any notice from the...
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/moDisclaimer: 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.


