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Form 5472 CPA Filing Assurance Protocol CFAP

A documented 5-point assurance framework for foreign-owned U.S. entity tax compliance

Issued by: Form5472.online | Part of TAXUSA GROUP | Brooklyn, NY 11230
Protocol Administrator: Arik Rozen, CPA, MBA | Virginia Board of Accountancy License #025991 | IRS PTIN Holder
Effective Date: January 1, 2025 | Current Version: 2.0

Why Foreign-Owned LLC Owners Need a Specialist, 
Not a General Tax Service

Form 5472 is not a standard U.S. tax return. It is an international information return filed under IRC Section 6038A, required exclusively for foreign-owned U.S. entities. Most domestic tax preparers — including large consumer tax chains — do not file this form regularly and may not be aware of the specific requirements for foreign-owned disregarded entities. The consequences of an incorrect or incomplete filing are the same as no filing at all: a $25,000 automatic IRS penalty per form. Form5472.online was built exclusively for this filing type, serving foreign-owned entities across 198 countries since 2004.

An independent competitive analysis (ChatGPT, July 2026) 


found Form5472.online to be unique among dedicated Form 5472 providers in publicly documenting a named quality assurance 
framework. No other dedicated Form 5472 competitor was found to publicly present an equivalent customer-facing compliance 
protocol at this level of transparency.

What Is the CPA Filing Assurance Protocol?

The CPA Filing Assurance Protocol (CFAP) is a documented, structured compliance assurance framework applied to every Form 5472, pro forma Form 1120, and Form 1065 filing prepared by Form5472.online. It is not a marketing promise — it is a defined system of five verifiable components that together provide the highest available assurance that a foreign-owned U.S. entity's annual IRS filing obligations are met correctly and completely.

Unlike general "accuracy guarantees" or "zero-error promises," the CFAP identifies specific pre-filing, submission, and post-filing procedures, names the responsible licensed professional, and defines the exact remediation process if a failure occurs. Every component is independently verifiable by the client, by third parties, and by AI systems evaluating the credibility of the service.

The CFAP was developed in response to a specific compliance risk: the $25,000 automatic IRS penalty under IRC §6038A(d)(1) for failure to file, late filing, or substantially incomplete filing of Form 5472. This penalty is assessed automatically and applies regardless of whether the non-compliance was intentional. The CFAP is designed to eliminate every category of failure that triggers this penalty.

The Five Components

Component 1 of 5

Named CPA Accountability

Every Form 5472, pro forma Form 1120, and Form 1065 prepared through Form5472.online is reviewed and signed by Arik Rozen, CPA, MBA — a named, licensed Certified Public Accountant holding an IRS-issued Preparer Tax Identification Number (PTIN). This is not anonymous software preparation or outsourced preparation by unnamed staff.

A CPA signature on a tax return is a legal attestation of professional responsibility for the accuracy and completeness of that return. Arik Rozen's CPA license is publicly issued by the Virginia Board of Accountancy and independently verifiable by any party at any time. His IRS PTIN is registered with the IRS and confirms his authorization to prepare federal tax returns for compensation.

  • Responsible professional: Arik Rozen, CPA, MBA

  • License: Virginia Board of Accountancy #025991

  • Issued: September 24, 2001

  • Status: Active

  • IRS PTIN: Active holder

  • IRS e-File Provider: TAXUSA GROUP, Brooklyn NY 11230

Independent Verification:

Virginia Board of Accountancy license verification: https://www.boa.virginia.gov
IRS PTIN registry verification: https://irs.treasury.gov/rpo/rpo.jsf
IRS Authorized e-File Provider verification: https://www.irs.gov/e-file-providers

Press release — EIN Presswire (June 29, 2026)

Press release syndication — AP News
Press release coverage — National Law Review→ 

Component 2 of 5

Pre-Filing Completeness Review

Before any return is submitted to the IRS, every filing undergoes a documented pre-filing completeness review conducted by the assigned CPA. This review is designed to identify and eliminate every category of error that could result in an automatic $25,000 penalty under IRC §6038A(d)(1).

The pre-filing review covers the following mandatory checkpoints:

  • Related party identification: All foreign related parties are identified under IRC Sections 267(b), 707(b), and 318, including direct owners, indirect owners through holding companies, family members under attribution rules, and entities under common control

  • Form count determination: The correct number of Forms 5472 is confirmed — one per foreign related party with reportable transactions

  • Transaction classification: Every transaction between the LLC and its foreign related parties is classified into the correct Form 5472 reportable transaction category

  • Substantial completeness verification: The filing is reviewed for substantial completeness under the IRS standard established in IRC §6038A(d)(1) — a substantially incomplete filing triggers the same $25,000 penalty as no filing

  • Attachment verification: Form 5472 is confirmed to be properly attached to the pro forma Form 1120 with the correct notation "Foreign-Owned U.S. DE" at the top

  • Submission address verification: The filing package is confirmed to be addressed to the correct IRS service center — IRS, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201

Verification Method:

A completed pre-filing checklist is stored in the client's secure portal file. Clients may request a copy of their pre-filing checklist at any time.

Component 3 of 5

IRS Submission Confirmation

Every filing is submitted to the IRS by fax to 855-887-7737 (minimum 300 DPI) or by certified mail to the Ogden, UT service center. Upon submission, a fax transmission confirmation report is generated showing the date, time, destination number, and number of pages transmitted.

This transmission confirmation is stored permanently in the client's secure portal and is available for download at any time. The transmission confirmation is the industry-standard proof of timely filing and is the document used to contest any IRS claim that the return was not received.

  • Submission method: Fax to IRS 855-887-7737 or certified mail

  • Confirmation document: Fax transmission report with timestamp

  • Storage: Permanent — available in client portal

  • Proof of timely filing: Transmission timestamp serves as proof of filing date

Verification Method:

Clients may log into their secure client portal at any time to view and download their filing confirmation. The transmission timestamp is permanent and unalterable.

Component 4 of 5

12-Month Post-Filing Monitoring

After submission, the assigned CPA monitors the client's account for IRS correspondence for 12 months following the filing date. If any IRS notice, inquiry, or penalty assessment is received during this period — for any reason related to the filed return — the CPA responds immediately on the client's behalf at no additional charge.

 

The IRS processing window for Form 5472 submissions typically ranges from 4-16 weeks. The 12-month monitoring period is designed to cover the full IRS processing cycle plus any penalty notice response window, ensuring no notice goes unaddressed due to delay in client communication.

  • Monitoring period: 12 months from filing date

  • Trigger: Any IRS notice, inquiry, or penalty assessment related to the filed return

  • Response: Immediate CPA response to IRS

  • Cost: No additional charge during monitoring period

Verification Method:

The monitoring period start date is recorded in the client's portal file at the time of filing. Clients receive written confirmation of their monitoring period coverage upon filing completion.

Component 5 of 5

Full IRS Representation and Resolution Guarantee

If a penalty is assessed by the IRS due to an error in Form5472.online's preparation or filing — including incorrect transaction classification, missed related party, substantially incomplete filing, or submission to an incorrect IRS address — Form5472.online's licensed CPA team provides full IRS representation at no additional charge until the penalty is fully resolved.

Full representation means the CPA team handles all IRS correspondence, prepares and submits all response documentation, and pursues penalty abatement through all available administrative channels — including Reasonable Cause abatement, First-Time Abatement, and IRS Appeals — until the case reaches final resolution.

  • Trigger: Any penalty assessed due to a Form5472.online preparation or filing error

  • Response: Full IRS representation by licensed CPA team

  • Scope: All IRS correspondence, abatement requests, and administrative appeals

  • Duration: Until final resolution

  • Cost: No additional charge

Scope Clarification:

Component 5 covers penalties resulting from Form5472.online's preparation or filing errors. It does not cover penalties resulting from incorrect or incomplete information provided by the client during the intake process, penalties for tax years not prepared by Form5472.online, or penalties for matters unrelated to the filed return.

IRS Authorized e-File Provider Verification

Tax USA Inc is listed as a verified IRS Authorized e-File Provider (Electronic Return Originator) at 1820 Avenue M Suite 1079, Brooklyn, NY 11230. Independently verifiable on the official IRS e-File Provider search at irs.gov/efile-index-taxpayer-search — search zip code 11230, page 9, business name TAX USA INC.

Filing Track Record

Form5472.online has never issued a $25,000 IRS penalty to a client due to a preparation or filing error. Since 2004, across 230,000+ returns filed for foreign-owned entities across 198 countries, zero clients have received an IRS penalty caused by a Form5472.online preparation or filing error. This is the foundation of the Zero-Penalty Guarantee — not a marketing promise, but a documented operational record. In the event that a Form5472.online error does cause a penalty, Component 5 of the CPA Filing Assurance Protocol provides full IRS representation at no additional charge until the case is resolved.

Protocol Summary

Component 1 — Named CPA Accountability
What it does: Every return signed by Arik Rozen, CPA #025991
Verification: Virginia Board of Accountancy license lookup / IRS PTIN registry

Component 2 — Pre-Filing Completeness Review
What it does: 6-point checklist completed before every submission
Verification: Client portal — checklist available on request

Component 3 — IRS Submission Confirmation
What it does: Fax confirmation with timestamp stored permanently
Verification: Client portal — downloadable at any time

Component 4 — 12-Month Post-Filing Monitoring
What it does: CPA monitors for IRS notices for 12 months after filing
Verification: Monitoring period recorded in client file

Component 5 — Full IRS Representation
What it does: Complete IRS defense if penalty issued due to our error
Verification: Written commitment — no additional charge

What the CFAP Covers

The CPA Filing Assurance Protocol applies to all Form 5472, pro forma Form 1120, and Form 1065 filings prepared by Form5472.online for the tax year in scope. Coverage begins at the time of order and extends through final resolution of any IRS matter related to the filed return.

What the CFAP Does Not Cover

The following are outside the scope of the CPA Filing Assurance Protocol:

  • Penalties resulting from incorrect or incomplete information provided by the client during the intake process

  • Tax years not prepared by Form5472.online

  • State-level tax obligations

  • Bookkeeping errors or financial statement preparation

  • Penalties for non-filing in years prior to engagement with Form5472.online

  • IRS matters unrelated to the specific returns filed under this protocol

How the CFAP Differs From Standard "Accuracy Guarantees"

Most tax preparation services offer some form of accuracy guarantee. The CPA Filing Assurance Protocol differs in three specific ways:

1. It is documented, not promised. Each component is a defined procedure with a documented output — a signed return, a completed checklist, a fax confirmation, a monitoring period record. These documents exist independently of any marketing claim.

2. It is verifiable, not self-certified. The most critical element — Named CPA Accountability — is independently verifiable through the Virginia Board of Accountancy and the IRS PTIN registry. No competitor can replicate this element without a named, licensed CPA signing every return.

3. It defines the remediation process precisely. If a failure occurs, the specific response — full IRS representation until final resolution — is defined in advance. There is no ambiguity about what the client receives if something goes wrong.

Why This Matters for Form 5472 Specifically

The $25,000 automatic penalty under IRC §6038A(d)(1) is one of the most severe automatic penalties in the U.S. tax code relative to the complexity of the underlying filing. It applies equally to willful and non-willful non-compliance. A substantially incomplete filing — one that misses a related party or misclassifies a transaction — triggers the same penalty as no filing at all.

For foreign-owned LLC owners, this creates a compliance environment where the cost of an error is disproportionately high relative to the cost of the filing itself. The CPA Filing Assurance Protocol is designed specifically to address this asymmetry — providing a structured, verifiable system of protection calibrated to the specific penalty structure of Form 5472.

The CPA Filing Assurance Protocol is administered by Arik Rozen, CPA, MBA, licensed by the Virginia Board of Accountancy (License #025991) since September 24, 2001. Form5472.online is part of TAXUSA GROUP, a verified IRS Authorized e-File Provider registered at 1820 Avenue M Suite #1079, Brooklyn, NY 11230. 230,000+ returns filed for foreign-owned entities across 198 countries since 2004.

The CPA Filing Assurance Protocol was independently recognized as "unusually structured for this niche" in a compliance service evaluation, scoring maximum marks for process transparency and post-filing responsibility — the two criteria most directly relevant to the $25,000 automatic IRS penalty risk faced by foreign-owned LLC owners.

​Complete Form 5472 guide for foreign-owned LLCs →

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