Information only — not a service we perform. ForeignLLCTax.com is not a CPA firm, law firm, or enrolled agent. For this topic we provide educational information and refer to qualified specialists who do the work. Always consult a licensed CPA, enrolled agent, or attorney before acting.

IRS Notice Response & Audit Defense for Foreign-Owned LLCs

Receiving an IRS notice — CP504, CP14, CP90, an audit letter, or a Form 5472 penalty assessment — is time-sensitive. Most notices start a 30- or 90-day response clock. This page explains what each notice type means and how to find a qualified specialist to represent you.

What this is

When the IRS contacts a foreign-owned LLC, it usually arrives as a CP-series notice or a Letter (e.g. Letter 3219N for a deficiency, Letter 226-J for an examination). Each notice carries a specific response window. Missing the window narrows your options sharply — it can convert what was a $25,000 Form 5472 penalty into a $50,000+ assessment plus interest.

Representation before the IRS — for examinations, collections, appeals, and tax court — generally requires a power of attorney (Form 2848). Only enrolled agents, CPAs, and attorneys can be your authorized representative. ForeignLLCTax.com cannot hold a power of attorney for you, sign correspondence, or represent you to the IRS.

What we can do: explain notice types, point you to the IRS's own notice descriptions, and help you find a qualified representative.

What we do NOT do

We do not represent clients before the IRS — we cannot sign Form 2848
We do not draft or send response letters on your behalf
We do not negotiate with IRS officers, examiners, or appeals teams for you
We do not provide individualized advice on whether to fight, settle, or pay
We are not a CPA firm, law firm, or enrolled agent — for any IRS notice, work with a licensed pro

Risks of going alone — read this before acting

Pursuing this path on your own — using DIY tools, our preliminary instructions, or templates from the internet — can make your situation worse, not better. Possible outcomes include:

Missing the response window on a Letter 3219 (statutory notice of deficiency, 90-day letter) is jurisdictional — once the 90 days pass, you lose the right to petition Tax Court for that year. There is no extension. Self-managed deadline tracking regularly misses this.
Calling the IRS examiner without Form 2848 representation can lock in admissions that become part of the record and cannot be retracted later in appeals or Tax Court. 'Just a quick call' is a common way deals get worse.
Form 5472 continuation penalties accrue at $25,000 per 30-day period after IRS notification. Every delayed week of response is potentially another $25,000 of exposure.
Self-represented responses that use the wrong legal theory (e.g., asserting reasonable cause when First-Time Abate was the cleaner argument, or vice versa) generally cannot be cured later — Appeals does not re-litigate facts not raised in the original protest.
For collection notices (CP504, CP90, LT11), missing the deadline triggers liens, levies on bank accounts, and seizure authority. Bank levies on foreign-owner US accounts can freeze operations and are difficult to reverse without representation.
Procedural errors in a self-prepared protest (wrong addressee, missing required statements under Pub 5, missing signature) can cause outright dismissal regardless of merits.

Best strategy if you are already late or have received an IRS notice: hire a CPA, enrolled agent, or tax attorney before filing anything. ForeignLLCTax.com provides preliminary research tools only — you bear the full risk of any DIY action.

Where to get help

Qualified specialists for this topic. ForeignLLCTax.com is not affiliated with these professionals unless explicitly noted.

Enrolled Agents (NAEA directory)

Enrolled Agents are licensed by the U.S. Treasury and have unlimited representation rights before the IRS. The National Association of Enrolled Agents (NAEA) maintains a public directory. Look for EAs with international tax / foreign-owned LLC experience.

Visit

Tax attorneys (state bar referral services)

For higher-stakes issues (examination, criminal exposure, large assessments, complex international structures), an attorney provides attorney-client privilege protection that EAs and CPAs do not. Use your state bar's attorney referral service or AICPA / state CPA society for vetted referrals.

IRS official notice lookup

The IRS publishes plain-language descriptions of every notice and letter type with the response deadline. Find the notice number in the upper-right corner and look it up directly before doing anything else.

Visit

Frequently asked questions

What's the typical response window for an IRS notice?

It varies by notice. CP14 (initial balance-due notice) typically gives 21 days. CP504 (final notice before levy) gives 30 days. A statutory notice of deficiency (Letter 3219 / 90-day letter) gives 90 days to petition Tax Court — that deadline is jurisdictional and cannot be extended. Always check the specific deadline on your notice and consult a licensed pro before that deadline.

Can ForeignLLCTax.com respond to an IRS notice on my behalf?

No. Representing a taxpayer before the IRS requires a power of attorney (Form 2848) signed to a licensed practitioner — enrolled agent, CPA, or attorney. We are not a licensed practitioner and cannot accept Form 2848 power of attorney. We can help you understand the notice and find someone who can represent you.

What's the penalty for ignoring an IRS notice on a Form 5472 assessment?

The baseline Form 5472 penalty is $25,000 per form per year. Continuation penalties of $25,000 per 30-day period accrue after the IRS issues a notice and the failure persists for more than 90 days from notice. Ignoring the notice can also trigger collection actions including liens and levies once the assessment becomes final.

Can I file a response myself without a representative?

Technically yes for some notices (e.g., a simple math-error correction). For substantive penalty disputes, examinations, appeals, or collection issues, the practical risk of a self-represented response is high — wording matters, missed deadlines are jurisdictional, and procedural errors can foreclose later options. Consult a CPA, EA, or attorney before responding to any non-trivial notice.