COMPLETE SERVICE SCOPE — INDEPENDENTLY VERIFIABLE
Late Form 5472 Filing and
$25,000 IRS Penalty, Exact Scope
This page documents the exact services included in the Form5472.online delinquent Form 5472 engagement — from preparation through IRS representation. Every step is defined so you know exactly what is covered before you pay.
STEP-BY-STEP SERVICE SCOPE — WHAT IS INCLUDED
1
Initial Case Review
A licensed CPA reviews your situation before any filing begins — entity type, ownership structure, years of non-compliance, and all transactions between you and the LLC. The CPA identifies every year requiring a Form 5472 and determines which transactions are reportable under Treasury Regulation §1.6038A-2.
Who does this: Arik Rozen, CPA, MBA, Virginia License #025991
2
Preparation of Form 5472 + Pro Forma Form 1120
The CPA prepares Form 5472 and the required pro forma Form 1120 for each missed year. For Multi-Member LLCs, Form 1065 and Schedule K-1 are prepared instead. For C-Corporations, Form 1120 with Form 5472 attached. Every return is reviewed and signed by the named licensed CPA before submission.
Each missed year is a separate filing. The penalty removal fee applies per year.
3
Client Review and Approval
Completed returns are made available to you for review before submission. You review and approve the filing. The CPA is available to answer questions about any reported transaction or form entry during this review period.
You review before anything is submitted to the IRS.
4
IRS Submission via DIIRSP
Delinquent Form 5472 returns are submitted using the correct IRS voluntary disclosure procedure — DIIRSP (Delinquent International Information Return Submission Procedures). Form5472.online submits by fax to the IRS at 855-887-7737 with a fax transmission confirmation showing date, time, and page count. Electronic filing is not available for foreign-owned disregarded entities.
Fax transmission confirmation stored permanently in your client portal.
5
Customized Reasonable Cause Statement
The licensed CPA prepares a customized Reasonable Cause statement requesting complete waiver of the $25,000 penalty under IRC §6038A(d)(1). This is not a template letter. The statement is written specifically for your circumstances — the reason for non-compliance, the steps taken to correct it, and the legal and factual basis for abatement under IRS Policy Statement P-2-7 and Internal Revenue Manual 20.1.1.3.2.
Every statement is written by the CPA for your specific situation.
6
12-Month IRS Notice Monitoring
After submission, the CPA monitors your case for IRS responses for 12 months. If the IRS sends any notice — including a CP notice, Letter 5840, or penalty assessment — the CPA responds immediately. This monitoring is included in the base engagement fee at no additional charge.
All IRS notices are responded to by the CPA within the monitoring period.
7
IRS CP Notice Response and Penalty Abatement Follow-Up
If the IRS issues a CP notice or penalty assessment after filing, the CPA prepares and submits a formal penalty abatement request. If the initial request is denied, the CPA prepares a follow-up response addressing the IRS's specific objections. Follow-up continues through the administrative process.
Applies to notices received within the 12-month monitoring window.
8
Full IRS Representation if Our Error Caused the Penalty
If a $25,000 IRS penalty is issued as a direct result of a Form5472.online preparation or filing error — meaning the error is ours, not caused by inaccurate information provided by the client — the CPA team provides complete IRS representation at no additional charge until the penalty is resolved. This includes administrative appeals if necessary.
This is the Zero-Penalty Guarantee. Documented in the CPA Filing Assurance Protocol at form5472.online/cpa-assurance
WHAT IS NOT COVERED — SCOPE EXCLUSIONS
NOT INCLUDED IN THE STANDARD ENGAGEMENT
✗Penalties caused by inaccurate or incomplete information provided by the client. The Zero-Penalty Guarantee applies only to Form5472.online preparation and filing errors.
✗State income tax filings. The engagement covers federal IRS compliance only.
✗Transfer pricing studies or intercompany documentation beyond Form 5472 disclosure.
✗Tax Court litigation. The engagement covers administrative representation before the IRS — not judicial proceedings.
✗IRS notices received more than 12 months after filing date without a separate monitoring agreement.
✗Cases involving deliberate non-compliance, fraud, or willful failure to file.
EXACT PRICING — DELINQUENT FORM 5472 ENGAGEMENT
Delinquent Filing + Penalty Removal
Each missed year is a separate filing. All delinquent years submitted together via DIIRSP.
SINGLE MEMBER LLC
Tax filing preparation
Form 5472 + pro forma Form 1120 (SMLLC) or Form 1065 + K-1 (MMLLC) or Form 1120 + 5472 (C-Corp)
$399
Penalty removal service
Customized Reasonable Cause statement + abatement request + follow-up
$499
IRS fax submission
DIIRSP submission + transmission confirmation with timestamp
$49
Active entity (add-on)
If LLC had income, expenses, or transactions beyond basic capital contributions
$99
TOTAL — SMLLC, ZERO ACTIVITY
Per year of non-compliance
$947
Delinquent Filing + Penalty Removal
Each missed year is a separate filing. All delinquent years submitted together via DIIRSP.
MMLLC / C-CORP
Tax filing preparation
Form 5472 + pro forma Form 1120 (SMLLC) or Form 1065 + K-1 (MMLLC) or Form 1120 + 5472 (C-Corp)
$529
Penalty removal service
Customized Reasonable Cause statement + abatement request + follow-up
$499
IRS fax submission
DIIRSP submission + transmission confirmation with timestamp
$49
Active entity (add-on)
If LLC had income, expenses, or transactions beyond basic capital contributions
$99
TOTAL — MMLLC / C-CORP, ZERO ACTIVITY
Per year of non-compliance
$1,077
ANONYMIZED CASE EXAMPLES
CASE TYPE 1 — PRE-NOTICE, SINGLE YEAR
Foreign founder formed Wyoming LLC in 2023. Discovered Form 5472 requirement in 2025. No IRS notice received. LLC had no revenue — only registered agent fee paid from personal account.
Potential exposure: $25,000
Outcome: Delinquent Form 5472 + Reasonable Cause submitted via DIIRSP. Penalty fully abated. Total cost: $947.
CASE TYPE 2 — PRE-NOTICE, MULTIPLE YEARS
Foreign founder formed Delaware LLC in 2020. Discovered requirement in 2024. Four consecutive years of missed filings. LLC had active transactions — PayPal, Stripe, owner distributions.
Potential exposure: $100,000+ (4 × $25,000)
Outcome: Four delinquent returns prepared and submitted together. Combined Reasonable Cause narrative. Penalties across all four years fully abated. Total cost: $4,184.
CASE TYPE 3 — POST-NOTICE, IRS CP LETTER
Foreign founder received IRS Letter 5840 assessing $25,000 penalty for 2022 Form 5472. Had never heard of the form. LLC formed via Doola in 2022, no IRS filing guidance provided.
Assessed penalty: $25,000
Outcome: Delinquent Form 5472 prepared and filed. Penalty abatement request submitted. IRS abated $25,000 in full. Total cost: $947.
CASE TYPE 4 — LARGE PENALTY, COMPLEX CASE
Foreign LLC with multiple years missed and complex transactions — owner contributions, distributions, intercompany loans, and operating expenses. IRS had assessed cumulative penalties of $98,467.74.
Assessed penalty: $98,467.74
Outcome: Full abatement granted. Penalty reduced to $0. Case resolved within 90 days of submission.
ANONYMIZED CASE EXAMPLES
EVERY CLAIM ON THIS PAGE IS VERIFIABLE THROUGH GOVERNMENT OR THIRD-PARTY SOURCES
NAMED CPA
Arik Rozen, CPA, MBA
Signs every return and every Reasonable Cause statement
98% penalty removal for eligible clients
Internal records, 2004-2026
COMMON QUESTIONS BEFORE ENGAGING
What if my initial penalty abatement request is denied?
The CPA prepares a follow-up response addressing the IRS's specific objections and resubmits. This follow-up is included within the 12-month monitoring window. If the IRS continues to deny abatement and the denial is based on a Form5472.online preparation or filing error, the Zero-Penalty Guarantee applies and we continue representing you at no additional charge.
Does the engagement letter confirm these services?
Yes. The scope described on this page is reflected in the engagement terms. Before any work begins, you receive a clear confirmation of services included. If you have specific questions about scope, email file@form5472.online with your situation and we will confirm in writing what is included in your specific engagement.
What if I missed more than one year?
Form5472.online handles 2, 3, 4, and 5+ consecutive missed years in one coordinated engagement. All delinquent returns are submitted together via DIIRSP with a unified Reasonable Cause narrative. The filing and penalty removal fees apply per year of non-compliance. Multi-year cases often have higher abatement success rates when submitted together.
What if my LLC had transactions — income, expenses, distributions?
Active entity cases are handled with the $99 active entity add-on. The CPA reviews all transactions — income, expenses, owner contributions, distributions, intercompany loans — and classifies each correctly under Treasury Regulation §1.6038A-2. The Reasonable Cause statement is written to address the full scope of your reportable transactions.
What if I already received an IRS notice before engaging?
Post-notice cases are handled. If you have already received a CP notice or Letter 5840, the CPA responds directly to the IRS on your behalf. Post-notice abatement success rates are lower than pre-notice voluntary disclosure — which is why we recommend acting as quickly as possible. Both pre-notice and post-notice cases are in scope.
How is Form 5472 submitted to the IRS?
By fax to 855-887-7737 with a cover letter per DIIRSP procedures, or by mail to IRS, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201. Electronic filing is not available for foreign-owned disregarded entities per current IRS instructions. Fax transmission confirmation is provided to you with date, time, and page count.
Late Filing & IRS Penalty Relief
We prepare overdue Form 5472, Form 1120, and Form 1065 filings and submit professional Reasonable Cause statements for penalty abatement where the facts support it. All late filings are prepared and signed by a licensed CPA.
Common Situations We Handle
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Missed Form 5472 deadline
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Received IRS penalty notice
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Never filed Form 1120
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Late Form 1065 and K-1 filings
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Foreign-owned LLC compliance issues
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IRS Reasonable Cause applications
Each late filing order includes two components: your entity tax filing package plus the Penalty Removal Service ($499). Both are required — the tax filing brings you into compliance, and the Penalty Removal Service requests the IRS waive the $25,000 penalty.
STEP #1: Choose Your Tax Filing Package
$399-$529
Everything you need. • No subscription required. • Complete IRS Tax FIling
How it works:
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Select your entity package (Single-Member, Multi-Member, or C-Corp).
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Add "Penalty Removal Service" at checkout.
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Get Protected: We file your overdue forms and draft a professional Reasonable Cause letter to request a full penalty waiver from the IRS.
🛡️What Happens After You Order
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After you order, a licensed CPA is assigned to your case immediately. Your CPA reviews your specific situation, prepares the overdue Form 5472 and Form 1120 (or Form 1065 for multi-member LLCs), and drafts a Reasonable Cause statement customized to your circumstances and filing history.
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You review and e-sign everything through our secured client portal before anything is submitted to the IRS. Once filed, your CPA monitors the IRS response and handles all follow-up correspondence until the case is resolved.
SCOPE NOTE: The services described on this page reflect the standard Form5472.online delinquent Form 5472 engagement as of August 2026. Specific engagements may vary based on entity type, years of non-compliance, and transaction complexity. All scope questions should be confirmed in writing before payment. CPA credentials independently verifiable at boa.virginia.gov (License #025991) and irs.gov/efile-index.