Form 5472 + 1120 filing service

DIIRSP: Filing Late Form 5472 with Penalty Abatement

The IRS Delinquent International Information Return Submission Procedure (DIIRSP) is the official way to catch up on missed Form 5472 filings while requesting that the $25,000-per-form-per-year penalty be waived. Filing under DIIRSP requires a properly written Reasonable Cause Statement attached to each late return. Get it right and most first-time filers walk away with no penalty assessed. Get it wrong — or do nothing — and the IRS will eventually mail a CP-15 notice and start the clock on continuation penalties.

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  • IRS forms

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What is DIIRSP, really?#

DIIRSP — Delinquent International Information Return Submission Procedure — is an IRS-published voluntary disclosure path specifically for international information returns like Form 5472, Form 5471, Form 8865, and Form 8938. It is not amnesty. It is not a guaranteed waiver. It is the IRS saying: "If you submit your delinquent international information returns with a reasonable cause statement, we will evaluate the request and decide whether to assess the penalty." The procedure exists because the IRS recognizes most foreign-owned LLC owners don't know about Form 5472 until after they've missed years of filings. Without DIIRSP, the penalty system would punish honest catch-up too harshly. With DIIRSP, well-documented voluntary catch-ups have a high acceptance rate.

Who qualifies for DIIRSP?#

DIIRSP is available to any taxpayer who: • Has not been contacted by the IRS about the specific delinquency yet (no CP-15 notice, no audit letter, no examination opened). • Has not been notified that they are under criminal investigation. • Is not currently under examination or audit for the tax year in question. • Does not owe any US income tax for the year in question (DIIRSP is for information-return delinquencies, not unpaid-tax cases). If the IRS has already sent you a CP-15 notice for the $25,000 penalty, you can still respond — but the path is penalty abatement appeal, not DIIRSP. DIIRSP is preventative; once a notice is issued you're in the formal appeal process. Most foreign-owned single-member LLCs satisfy all four criteria — they have $0 US tax liability and have never been contacted by the IRS. DIIRSP is the right path for almost all of them.

How does DIIRSP work — step by step?#

1. Identify every missed year. If you formed the LLC in 2022 and haven't filed, that's 2022, 2023, 2024. 2. Prepare the complete filing package for each missed year separately: cover letter, pro forma Form 1120 (with "Foreign-Owned U.S. DE" stamp), Form 5472, Part V supporting statement. 3. Write a single Reasonable Cause Statement that covers all missed years (or one per year if circumstances differ). 4. Attach the statement to the front of the package. 5. File all years together — fax the entire set to +1-855-887-7737 (IRS Ogden PIN Unit), or mail certified to IRS Ogden, UT 84201-0023. 6. Keep the fax transmission receipt. It's the timestamped proof that you submitted under DIIRSP on a specific date — important if the IRS later tries to assess penalties. 7. Wait. The IRS typically responds within 3-6 months. No response usually means accepted.

What makes a good Reasonable Cause Statement?#

The IRS evaluates whether you acted with "ordinary business care and prudence." Strong statements include: • A clear timeline of when and how you became aware of the filing requirement. • Specific personal circumstances — first-time foreign LLC owner, reliance on a tax professional who didn't flag the obligation, language barrier, the LLC was formed as part of a Stripe Atlas / startup accelerator package and the filing wasn't part of the onboarding, etc. • Evidence you took corrective action immediately upon learning (and how soon — "I learned in March 2026 and am filing in April 2026" is much stronger than "I learned in 2024 and am filing now"). • Explicit confirmation that no US tax is owed and that this is purely an information-return delinquency. • A statement that you will comply going forward, ideally citing the system you've put in place (e.g. annual filing reminder, signed up for an annual filing service). • Concise — typically 1-2 pages. Generic statements like "I didn't know" are weak. Specific, factual statements tied to your real circumstances work.

What weakens a Reasonable Cause Statement?#

Things that hurt your DIIRSP case: • Vague excuses ("I was busy", "I forgot", "my CPA didn't tell me" without further detail). • Statements that contradict facts visible on the form (e.g. claiming you didn't know about US filing obligations while reporting years of US-source revenue). • Boilerplate copied from forums or generic templates with no facts unique to your situation. • Aggressive language toward the IRS. • Implying tax avoidance was a motive. • Missing or contradictory dates in the timeline. • Claims of reliance on a professional without naming when you consulted them or what they advised. • Filing under DIIRSP when you have unpaid US tax (use Streamlined Filing Compliance Procedures or a different path instead).

How do you handle multi-year DIIRSP filings?#

If you've missed 2 or 3+ years, file them all at once with one comprehensive Reasonable Cause Statement covering the entire period. The IRS treats a single comprehensive catch-up far more favorably than serial late filings spaced out over time. Our flat-rate DIIRSP catch-up packages: • 2-year DIIRSP catch-up: Standard $348 · Rush $428 · Premium $598 (fax included) • 3-year DIIRSP catch-up: Standard $497 · Rush $577 · Premium $747 (fax included) The per-year price is cheaper than filing separately, and we use one consistent reasonable cause narrative across all years. Every package is reviewed by an accountant on our team before we fax it to the IRS. For 4+ missed years, you'd run two packages back-to-back or message us to coordinate — the IRS still accepts the comprehensive catch-up approach but the multi-year package limit is 3 years per wizard session.

What's the difference between DIIRSP, Streamlined, and Quiet Disclosure?#

Three commonly confused IRS catch-up paths: • DIIRSP — for delinquent international information returns (Form 5472, 5471, 8865, 8938) where no US tax is owed. Reasonable cause statement required. • Streamlined Filing Compliance Procedures — for US persons (citizens, green-card holders) with delinquent FBAR or income-tax filings. Requires a Streamlined Certification and is more complex. Almost never the right path for a foreign-owned US LLC with $0 US tax. • Quiet disclosure — informal term for filing late without explanation. Strongly discouraged. The IRS often assesses penalties anyway and there's no documented good-faith effort to abate. For foreign-owned single-member LLCs with no US tax liability, DIIRSP is the right path 99% of the time.

What happens after you file under DIIRSP?#

The IRS Ogden Service Center processes the package. Typical timeline: • 0-2 weeks: fax confirmed delivered. No IRS acknowledgment yet — that's normal. • 2-6 months: IRS reviews. If they accept the reasonable cause, you typically hear nothing. No news is good news. • 3-9 months: if they want more info, you'll get a Letter 5891 or similar. Respond promptly with the requested documentation. • 6-12 months: if they assess the penalty anyway despite the reasonable cause request, you'll get a CP-15. You can then appeal through the IRS Office of Appeals. Keep the entire DIIRSP package (signed PDF, reasonable cause statement, fax receipt) for at least 6 years. If the IRS contacts you in year 4 about year 2 filing, you'll want the original receipts to prove timely DIIRSP submission.

What should you NOT do under DIIRSP?#

• Do not pay any penalty before you file under DIIRSP — there's nothing to pay until the IRS assesses something. • Do not split missed years across multiple filings over months. File them all at once. • Do not submit only Form 5472 without the pro forma 1120 and supporting statement — incomplete filings can be treated as not filed and the DIIRSP request rejected. • Do not write a reasonable cause statement that admits negligence or implies tax avoidance. Frame the failure as a good-faith unawareness or reliance issue. • Do not assume amending an existing late return will reset the DIIRSP clock — amendments don't qualify as initial DIIRSP submissions if you previously filed late without one. • Do not skip the wet/ink signature requirement. Form 5472 and the attached 1120 require pen signatures; digital-only signatures can invalidate the filing.

Catch up with our accountant-reviewed DIIRSP filer#

Form5472 Prep automatically generates a Reasonable Cause Statement when you select 2 or 3 missed years in our wizard. The narrative is tailored to the most common DIIRSP scenario — first-time foreign LLC owner who was unaware of the Form 5472 obligation — and you can edit it to fit your specific circumstances. We prepare the complete package for each year (cover letter, pro forma 1120, Form 5472, Part V supporting statement, reasonable cause statement). You sign once on screen — that signature embeds into every required signature box automatically. An accountant on our team reviews everything end-to-end. We fax to the IRS Ogden PIN Unit and email you the timestamped receipt for each year as proof of DIIRSP submission. • 2-year DIIRSP catch-up: Standard $348 · Rush $428 · Premium $598 (fax included) • 3-year DIIRSP catch-up: Standard $497 · Rush $577 · Premium $747 (fax included) 100% money-back guarantee if we fail to submit.

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We generate every form, you sign one PDF, we fax it to the IRS Ogden PIN Unit. Starting at $199. IRS fax delivery included on every plan.

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+ $149 per additional year·Saves you from the $25,000-per-form IRS penalty

Frequently asked questions

Does DIIRSP guarantee my penalty is waived?
No. DIIRSP is the official IRS process for requesting abatement, but each request is evaluated on its facts. Well-written first-time DIIRSP submissions have a high acceptance rate, but there's no formal guarantee.
How long after a DIIRSP filing will I hear back?
Usually 3-6 months. The IRS will either accept the reasonable cause and close the matter quietly (no news), or send a CP-15 notice with the penalty assessed (which you can then appeal through the IRS Office of Appeals).
Can I do DIIRSP myself?
Yes. The hardest part is writing a strong Reasonable Cause Statement tied to your specific facts. Our service auto-generates one based on the most common DIIRSP scenario, and you can edit it in the wizard.
I missed 5 years — can I still file under DIIRSP?
Yes. There's no statutory limit on how many years you can catch up under DIIRSP. Our wizard supports up to 3 years per session; for 4+ missed years run two packages back-to-back or message us and we'll coordinate.
I already got a CP-15 notice — is DIIRSP still an option?
Not for that specific year — once the IRS has assessed a penalty, you're past the DIIRSP eligibility window for that year. You'd respond to the notice with a penalty abatement request and appeal if denied. For any other unfiled years where you haven't been contacted, DIIRSP is still available.
Do I need a lawyer for DIIRSP?
Almost never. DIIRSP is a paperwork process: prepare the late returns, write a reasonable cause statement, send it in. A lawyer adds value only if you're facing collection action, criminal exposure, or unusual circumstances. For a standard first-time foreign LLC catch-up, the wizard handles it.
What's the difference between DIIRSP and just filing late?
Filing late without a reasonable cause statement is a quiet disclosure — the IRS sees the late filing, assesses the $25,000 penalty automatically, and you're stuck responding to the CP-15. DIIRSP is the same filing PLUS a reasonable cause statement requesting abatement upfront. Much better outcomes.
Can DIIRSP cover both Form 5472 and other international returns at the same time?
Yes. DIIRSP covers all international information returns (5471, 5472, 8865, 8938). If your foreign-owned LLC has additional reporting obligations (rare for single-member disregarded entities), you'd include them in the same package.
Does the IRS publish DIIRSP acceptance statistics?
No. The IRS does not publish acceptance rates for DIIRSP submissions. From practitioner experience, well-documented first-time foreign-owner catch-ups are accepted at a high rate. Repeat delinquencies or filings with weak reasonable cause are accepted less often.
If accepted, do I still need to file in future years?
Yes. DIIRSP only addresses past delinquencies. From the year of catch-up onward, you must file Form 5472 + pro forma 1120 every year by April 15. Most of our DIIRSP customers come back annually for their on-time filing.

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